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    <description>The appeal was partly allowed. The issue concerning the determination of Arm&#039;s Length Price (ALP) for intra-group services was remanded to the Assessing Officer/Transfer Pricing Officer for reconsideration, emphasizing the need to assess whether the price paid aligns with what an independent enterprise would pay. The Tribunal directed the assessee to provide detailed documentation supporting the services received. Additionally, the disallowance under Section 14A of the Income Tax Act was deleted, as Section 44 was held to override Section 14A for insurance companies, governing the computation of income.</description>
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