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    <title>2019 (10) TMI 1441 - ITAT DELHI</title>
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    <description>The appellant&#039;s challenge against Transfer Pricing Officer&#039;s (TPO) adjustments regarding comparables was partially successful, with specific inclusions and exclusions directed by the Tribunal. The assignment of NIL value to international transactions related to Intra Group Services (IGS) was referred back to the TPO for further examination. The disallowance under section 40a(ia) for failure to deduct tax at source on payments made to non-residents was deleted by the Tribunal. The appeal was allowed in part, with directions for adjustments and deletions, pronounced on 23.10.2019.</description>
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      <description>The appellant&#039;s challenge against Transfer Pricing Officer&#039;s (TPO) adjustments regarding comparables was partially successful, with specific inclusions and exclusions directed by the Tribunal. The assignment of NIL value to international transactions related to Intra Group Services (IGS) was referred back to the TPO for further examination. The disallowance under section 40a(ia) for failure to deduct tax at source on payments made to non-residents was deleted by the Tribunal. The appeal was allowed in part, with directions for adjustments and deletions, pronounced on 23.10.2019.</description>
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