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    <title>Revenue&#039;s TP Adjustment Using Form 3CED Auditor&#039;s Certification Challenged; Form Doesn&#039;t Address Tested Party&#039;s Situation.</title>
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    <description>TP Adjustment - tested party for the purpose of determination of Arm&#039;s Length Price - Revenue seeks to pin the assessee based upon the auditor&#039;s certification as filed in Form 3CED. As could be seen from the statutory form, it pertains only to the transactional claims and has got nothing to do with a tested party. The revenue cannot compare the case of the assessee with that of the assessee who fails to claim in his return of income a deduction or a benefit which he would be otherwise entitled to. - HC</description>
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      <description>TP Adjustment - tested party for the purpose of determination of Arm&#039;s Length Price - Revenue seeks to pin the assessee based upon the auditor&#039;s certification as filed in Form 3CED. As could be seen from the statutory form, it pertains only to the transactional claims and has got nothing to do with a tested party. The revenue cannot compare the case of the assessee with that of the assessee who fails to claim in his return of income a deduction or a benefit which he would be otherwise entitled to. - HC</description>
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