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    <description>Additional evidence first produced before the ITAT, including an AE confirmation and a format agreement with another broadcaster, was treated as material to determine the arm&#039;s length price of deemed international transactions involving television content production fees. Because the evidence was relevant and necessary for proper adjudication, it was admitted under Rule 29 of the ITAT Rules and the transfer pricing adjustment was restored to the Assessing Officer and TPO for fresh consideration after giving the assessee an adequate opportunity of hearing. The appeal succeeded only on this transfer pricing ground, and the remaining grounds did not survive for adjudication.</description>
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