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    <title>2013 (6) TMI 104 - DELHI HIGH COURT</title>
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    <description>The Tribunal classified interest income as non-operating income, disallowing relatable expenses. The application of the 5% range under Proviso 92C(2) was found inapplicable, with data from previous years rejected for transfer pricing. Closure expenses were deemed abnormal and excluded from ALP computation. The Tribunal&#039;s decision was upheld regarding the non-consideration of evidence. Overhead expenses allocation favored the assessee. The revenue&#039;s appeal was dismissed, partially allowing the assessee&#039;s appeal. Only the treatment of closure expenses raised a legal question, resolved in favor of the assessee.</description>
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    <pubDate>Thu, 25 Apr 2013 00:00:00 +0530</pubDate>
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      <title>2013 (6) TMI 104 - DELHI HIGH COURT</title>
      <link>https://www.taxtmi.com/caselaws?id=234279</link>
      <description>The Tribunal classified interest income as non-operating income, disallowing relatable expenses. The application of the 5% range under Proviso 92C(2) was found inapplicable, with data from previous years rejected for transfer pricing. Closure expenses were deemed abnormal and excluded from ALP computation. The Tribunal&#039;s decision was upheld regarding the non-consideration of evidence. Overhead expenses allocation favored the assessee. The revenue&#039;s appeal was dismissed, partially allowing the assessee&#039;s appeal. Only the treatment of closure expenses raised a legal question, resolved in favor of the assessee.</description>
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      <pubDate>Thu, 25 Apr 2013 00:00:00 +0530</pubDate>
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