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    <title>2016 (7) TMI 238 - ITAT PUNE</title>
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    <description>The Tribunal partially allowed the appeal filed by the assessee for statistical purposes. Various issues such as transfer pricing adjustment, computation of operating profit, selection of comparable companies, and risk adjustment were remitted back to the AO/TPO for reconsideration. The Tribunal directed adjustments to be based on segmental profitability of international transactions with Associated Enterprises, correct computation of deductions, and consideration of risk adjustments to align comparables with the assessee. Some grounds, like the reduction from the arithmetic mean and certain working capital adjusted margins, were dismissed or not pressed by the assessee.</description>
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      <link>https://www.taxtmi.com/caselaws?id=329640</link>
      <description>The Tribunal partially allowed the appeal filed by the assessee for statistical purposes. Various issues such as transfer pricing adjustment, computation of operating profit, selection of comparable companies, and risk adjustment were remitted back to the AO/TPO for reconsideration. The Tribunal directed adjustments to be based on segmental profitability of international transactions with Associated Enterprises, correct computation of deductions, and consideration of risk adjustments to align comparables with the assessee. Some grounds, like the reduction from the arithmetic mean and certain working capital adjusted margins, were dismissed or not pressed by the assessee.</description>
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