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The ITAT upheld the order of the CIT(A) regarding the Transfer Pricing (TP) adjustment. The Tribunal concurred with the CIT(A)'s decision to exclude two companies with exports while determining the Arm's Length range. It also agreed that the Tested Party, M/s. Laila Nutra, which is the Associated Enterprise (AE) of the assessee, can be compared only with the comparables selected by the Transfer Pricing Officer (TPO), as they are functionally broadly similar to the AE as a Tested Party. The ITAT dismissed the Revenue's grounds of appeal, finding no infirmity in the CIT(A)'s order.
The ITAT upheld the order of the CIT(A) regarding the Transfer Pricing (TP) adjustment. The Tribunal concurred with the CIT(A)'s decision to exclude two companies with exports while determining the Arm's Length range. It also agreed that the Tested Party, M/s. Laila Nutra, which is the Associated Enterprise (AE) of the assessee, can be compared only with the comparables selected by the Transfer Pricing Officer (TPO), as they are functionally broadly similar to the AE as a Tested Party. The ITAT dismissed the Revenue's grounds of appeal, finding no infirmity in the CIT(A)'s order.
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