Admissibility of electronic evidence bars undervaluation demands where printouts, retracted statements and no cross-examination leave the case unprove...
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TP adjustment - international transaction - expenses - incurred wholly and exclusively for the purpose of business or not - In the present case, the AO, by applying benefit test to the impugned international transaction has attempted to step into the shoes of TPO, since the benefit test could have been applied only for the purpose of determining ALP of the transaction as pointed out by the DRP also from the OECD commentary and from the various decision of the ITAT on this issue. - Additions deleted - AT
TP adjustment - international transaction - expenses - incurred wholly and exclusively for the purpose of business or not - In the present case, the AO, by applying benefit test to the impugned international transaction has attempted to step into the shoes of TPO, since the benefit test could have been applied only for the purpose of determining ALP of the transaction as pointed out by the DRP also from the OECD commentary and from the various decision of the ITAT on this issue. - Additions deleted - AT
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