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Rectification in transfer pricing proceedings was required where the assessee claimed that an international transaction had been wrongly allocated between segments and sought corrected segmental financials; the matter was remitted for verification and fresh decision after hearing. Comparable margins, as well as working capital and risk adjustments, were also restored for examination by the AO/TPO, with no merits adjudicated and all surviving transfer pricing grounds sent back for fresh adjudication.
Rectification in transfer pricing proceedings was required where the assessee claimed that an international transaction had been wrongly allocated between segments and sought corrected segmental financials; the matter was remitted for verification and fresh decision after hearing. Comparable margins, as well as working capital and risk adjustments, were also restored for examination by the AO/TPO, with no merits adjudicated and all surviving transfer pricing grounds sent back for fresh adjudication.
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