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of The ITAT held that the TPO shall consider 1% rate as the arm's length price (ALP) for the international transaction involving issuance of Stand-by Letter of Credit (SBLC) to the associated enterprise (AE). The revenue expenditure claimed by the assessee, which exceeded the amount quantified by the DSIR, should be allowed as deduction u/s 37(1) after allowing the eligible portion u/s 35(2AB), as the AO erred in not examining whether the differential amount was for business purposes.
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