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    <title>2022 (12) TMI 670 - ITAT MUMBAI</title>
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    <description>The Tribunal allowed the appeal, directing the TPO/AO to delete the adjustment of Rs. 2,99,06,541/- based on the acceptance of Resale Price Method (RPM) as the most appropriate method for benchmarking the international transaction of trading activities. Other grounds such as economic adjustment due to currency devaluation and business reasons for losses were not separately adjudicated as they were rendered moot by the decision on the benchmarking method. Penalty proceedings initiation under section 271(1)(c) were not specifically addressed.</description>
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