Arms Length Pricing

Quotations Can Be Comparables for Arms Length Pricing Determination!

Selection of comparables is one of the most contentious issue between the taxpayer and the Transfer Pricing Officer (TPO) . This post is restricted to an issue whether the quotation from parties can be taken as comparabales for the purpose of the determination of arms length pricing (ALP) -whether for international transactions or specified domestic transactions . Biggest objection is that the quotation is not the actual data , so it should not be compared with actual data. But , that problem is no more..