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TP Adjustment - tested party - No infirmity in the order of the...
CIT(A) approves using foreign associated enterprise as tested party; advises against aggregating transactions for benchmarking. Excludes certain services.
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TP Adjustment - tested party - No infirmity in the order of the learned CIT(A) in directing the assessee to adopt the foreign associated enterprise as tested party with respect to 1st set of transactions, not to aggregate the first set of transaction and second set of transactions for benchmarking, exclusion of e–clerk services limited and TCS e–serve international Limited for benchmarking second set of transactions. - AT
TP Adjustment - tested party - No infirmity in the order of the learned CIT(A) in directing the assessee to adopt the foreign associated enterprise as tested party with respect to 1st set of transactions, not to aggregate the first set of transaction and second set of transactions for benchmarking, exclusion of e–clerk services limited and TCS e–serve international Limited for benchmarking second set of transactions. - AT
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