Budget 2013: OPPI proposes flexibility in using multiple year data
The single year data pertaining to the year of international transaction is most often not available at the time of carrying out the benchmarking analysis by the assessee," added OPPI.
OPPI sights that the Rule 10B(4) prescribes that only data relating to the year in which international transaction has been entered into will be used for comparability purposes and that data for two prior years may be used only in case such data has a bearing on the determination of arm’s length price.
OPPI is of the view that use of single year data fails to consider the impact of business cycles. "The single year data pertaining to the year of international transaction is most often not available at the time of carrying out the benchmarking analysis by the assessee," added OPPI.
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