Transfer-pricing aggregation of distinct support-service and subcontract transactions was rejected, while debt-free receivables attracted no notional ...
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Revision u/s 263 - specified domestic transactions - effect of omission of 92BA(1) w.e.f. 1.4.2017 - the order has been revised purely on the basis that the AO has not referred to determine the ALP to the TPO - Since the provision itself stood omitted at the time when the order was passed by the Pr. CIT, the impugned order cannot be sustained, hence is hereby quashed
Revision u/s 263 - specified domestic transactions - effect of omission of 92BA(1) w.e.f. 1.4.2017 - the order has been revised purely on the basis that the AO has not referred to determine the ALP to the TPO - Since the provision itself stood omitted at the time when the order was passed by the Pr. CIT, the impugned order cannot be sustained, hence is hereby quashed
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