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    <title>2013 (12) TMI 126 - ITAT MUMBAI</title>
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    <description>Transfer pricing on project and EPC services was held unsustainable on an entity-level margin where the assessee&#039;s man-hour based segmental accounts were not validly rejected and, in any event, the AE margin fell within the statutory tolerance band; the adjustment was deleted. On the corporate guarantee issue, the assessee failed to rebut the bank-based material relied on by the TPO or to show that the rate charged was at arm&#039;s length, and the addition was sustained. The remaining grounds were treated as infructuous or not pressed.</description>
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    <pubDate>Wed, 28 Aug 2013 00:00:00 +0530</pubDate>
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      <link>https://www.taxtmi.com/caselaws?id=240461</link>
      <description>Transfer pricing on project and EPC services was held unsustainable on an entity-level margin where the assessee&#039;s man-hour based segmental accounts were not validly rejected and, in any event, the AE margin fell within the statutory tolerance band; the adjustment was deleted. On the corporate guarantee issue, the assessee failed to rebut the bank-based material relied on by the TPO or to show that the rate charged was at arm&#039;s length, and the addition was sustained. The remaining grounds were treated as infructuous or not pressed.</description>
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      <pubDate>Wed, 28 Aug 2013 00:00:00 +0530</pubDate>
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