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    <title>2022 (8) TMI 521 - ITAT PUNE</title>
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    <description>The Tribunal allowed the appeal, setting aside the impugned order and remitting the matter to the AO/TPO for re-determining the Arm&#039;s Length Price (ALP) of the international transaction. The appeal was time-barred due to the Covid pandemic, but the delay was condoned. The Transfer Pricing adjustment of Rs. 29,47,928 was upheld, and certain comparables were excluded from the list. The treatment of Foreign Exchange Fluctuation (forex) loss as non-operating was challenged and overturned. The Tribunal directed a re-determination of the ALP considering these factors.</description>
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      <description>The Tribunal allowed the appeal, setting aside the impugned order and remitting the matter to the AO/TPO for re-determining the Arm&#039;s Length Price (ALP) of the international transaction. The appeal was time-barred due to the Covid pandemic, but the delay was condoned. The Transfer Pricing adjustment of Rs. 29,47,928 was upheld, and certain comparables were excluded from the list. The treatment of Foreign Exchange Fluctuation (forex) loss as non-operating was challenged and overturned. The Tribunal directed a re-determination of the ALP considering these factors.</description>
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