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    <title>2020 (3) TMI 331 - ITAT PUNE</title>
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    <description>The Tribunal upheld the validity of the reference made by the AO to the TPO for determining the ALP of specified domestic transactions and international transactions. It directed the treatment of foreign exchange gain/loss as operating revenue/cost for revenue transactions. The Tribunal addressed the comparability of certain companies, including/excluding them based on their functional profiles. It also ruled that the provision for bad and doubtful debts should be considered as an operating expense. The disallowance of Rs. 5.00 lakh from office expenses was upheld, but excluded from operating expenses for calculating the profit margin. The matter was remitted to the AO/TPO for fresh determination of the ALP.</description>
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