Faceless reassessment jurisdiction turned on retrospective AO definition, with later faceless-assessment changes treated as clarificatory and procedur...
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TP Adjustment - comparable selection - ALP which is worked out after applying the 5% range - Application of Tolerance Range - The ITAT found that the CIT(A) correctly applied the tolerance range, showing that the assessee's prices for ITES and IT segments were within the permissible limits, negating the need for any transfer pricing adjustments.
TP Adjustment - comparable selection - ALP which is worked out after applying the 5% range - Application of Tolerance Range - The ITAT found that the CIT(A) correctly applied the tolerance range, showing that the assessee's prices for ITES and IT segments were within the permissible limits, negating the need for any transfer pricing adjustments.
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