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Non-confirmation of FEMA seizure prevents adjudicators from overriding pending appellate findings on recorded reasons and suspected foreign asset hold...
TP Adjustment - Comparable selection - In view of the fact that the AR has simply harped on the high profit margin as a reason for seeking exclusion without pointing out any abnormal business conditions existing with that company for the year under consideration, we find no reason to disturb the conclusion drawn by the CIT(A) in echoing the inclusion of ICC International Agencies Ltd. (Segment) in the list of comparables. - AT
TP Adjustment - Comparable selection - In view of the fact that the AR has simply harped on the high profit margin as a reason for seeking exclusion without pointing out any abnormal business conditions existing with that company for the year under consideration, we find no reason to disturb the conclusion drawn by the CIT(A) in echoing the inclusion of ICC International Agencies Ltd. (Segment) in the list of comparables. - AT
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