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    <title>2022 (1) TMI 81 - ITAT DELHI</title>
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    <description>The appeal of the assessee was allowed, and the transfer pricing adjustment of Rs. 69,65,962/- made by the Transfer Pricing Officer (TPO) and upheld by the Commissioner of Income-tax (Appeals) was deleted. The Income Tax Appellate Tribunal (ITAT) held that the TPO and CIT(A) exceeded their jurisdiction, the evidences provided by the appellant were deemed sufficient, and the application of the Comparable Uncontrolled Price (CUP) method was found arbitrary. The necessity and commercial expediency of the services were upheld as within the appellant&#039;s commercial wisdom.</description>
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    <pubDate>Tue, 07 Dec 2021 00:00:00 +0530</pubDate>
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      <title>2022 (1) TMI 81 - ITAT DELHI</title>
      <link>https://www.taxtmi.com/caselaws?id=416616</link>
      <description>The appeal of the assessee was allowed, and the transfer pricing adjustment of Rs. 69,65,962/- made by the Transfer Pricing Officer (TPO) and upheld by the Commissioner of Income-tax (Appeals) was deleted. The Income Tax Appellate Tribunal (ITAT) held that the TPO and CIT(A) exceeded their jurisdiction, the evidences provided by the appellant were deemed sufficient, and the application of the Comparable Uncontrolled Price (CUP) method was found arbitrary. The necessity and commercial expediency of the services were upheld as within the appellant&#039;s commercial wisdom.</description>
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      <pubDate>Tue, 07 Dec 2021 00:00:00 +0530</pubDate>
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