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        Case ID :
        Income Tax

        TP Adjustment - ALP adjustment on account of receipt of...

        Tax Court Overturns Transfer Pricing Adjustment on Commission Income; Depreciation and Material Costs Impact Acknowledged.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                TP Adjustment - ALP adjustment on account of receipt of commission for Marketing Services - main contention of the appellant is that the functions undertaken by the assessee for selling the product is significantly different from what is undertaken for the purpose of earning the commission income from A.E - CIT-A deleted the adjustments - The reasoning given by the TPO that these two segments of the cost does not contribute to profit does not stand to any reason, in as much as the depreciation and the material actually contributes to the profits in the manufacturing segment. - AT
                                Note: It is a system-generated summary and is for quick reference only.
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