Bad debts written off cannot be a factor to determine the Arms length price under any of the Transfer Pricing methods prescribed in the Income Tax Act, 1961

disallowance made by the Transfer Pricing Officer (TPO) to the royalty, to the extent of the bad debts written off by the Taxpayer, was not in accordance with the transfer pricing (TP) provisions of the Indian Tax Law (ITL). According to the ITAT,...

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