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    <title>2019 (12) TMI 815 - ITAT MUMBAI</title>
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    <description>The Tribunal ruled in favor of the assessee, stating that transfer pricing provisions do not apply to companies covered under the Tonnage Tax Scheme (TTS). Consequently, the transfer pricing adjustment made by the Transfer Pricing Officer (TPO) was deemed inapplicable. The adjustment on account of allocation of head office expenses was also rejected as the TTS income is computed on a presumptive basis. Issues related to interest levy and penalty proceedings were considered academic following the primary ruling. An additional ground concerning Dividend Distribution Tax (DDT) was admitted for further examination by the Assessing Officer in light of relevant case law.</description>
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      <title>2019 (12) TMI 815 - ITAT MUMBAI</title>
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      <description>The Tribunal ruled in favor of the assessee, stating that transfer pricing provisions do not apply to companies covered under the Tonnage Tax Scheme (TTS). Consequently, the transfer pricing adjustment made by the Transfer Pricing Officer (TPO) was deemed inapplicable. The adjustment on account of allocation of head office expenses was also rejected as the TTS income is computed on a presumptive basis. Issues related to interest levy and penalty proceedings were considered academic following the primary ruling. An additional ground concerning Dividend Distribution Tax (DDT) was admitted for further examination by the Assessing Officer in light of relevant case law.</description>
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