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    <title>2012 (2) TMI 366 - ITAT MUMBAI</title>
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    <description>The Tribunal upheld the deletion of an addition of Rs. 49,99,680 made by the Transfer Pricing Officer (TPO) to the arm&#039;s length price (ALP) concerning international transactions with Associated Enterprises (AEs). The Commissioner of Income-tax (Appeals) [CIT(A)] had deleted this addition, and the Tribunal agreed, emphasizing that the profit margin on transactions with AEs was not lower than the combined margin. Additionally, the Tribunal dismissed the proposed addition of Rs. 87,66,461 for interest receivable on outstanding amounts from AEs, stating that interest income cannot be treated as a separate international transaction when part of a sale transaction. The appeal was ultimately dismissed.</description>
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    <pubDate>Wed, 22 Feb 2012 00:00:00 +0530</pubDate>
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      <title>2012 (2) TMI 366 - ITAT MUMBAI</title>
      <link>https://www.taxtmi.com/caselaws?id=210938</link>
      <description>The Tribunal upheld the deletion of an addition of Rs. 49,99,680 made by the Transfer Pricing Officer (TPO) to the arm&#039;s length price (ALP) concerning international transactions with Associated Enterprises (AEs). The Commissioner of Income-tax (Appeals) [CIT(A)] had deleted this addition, and the Tribunal agreed, emphasizing that the profit margin on transactions with AEs was not lower than the combined margin. Additionally, the Tribunal dismissed the proposed addition of Rs. 87,66,461 for interest receivable on outstanding amounts from AEs, stating that interest income cannot be treated as a separate international transaction when part of a sale transaction. The appeal was ultimately dismissed.</description>
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      <pubDate>Wed, 22 Feb 2012 00:00:00 +0530</pubDate>
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