Transfer pricing dispute became infructuous after advance pricing arrangement settlement and withdrawal of the connected appeal.

The transfer pricing dispute became infructuous after the underlying issues were settled through an advance pricing arrangement and the assessee withdrew its connected appeal on the same matters, so the revenue appeal was dismissed. The operative effect was that no further adjudication was required on the settled transfer pricing issues.

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Outcome: The revenue appeal was dismissed as infructuous because the transfer pricing dispute had already been settled through an advance pricing arrangement and the assessee had withdrawn its connected appeal on the same issues.

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