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    <title>2021 (2) TMI 1318 - ITAT MUMBAI</title>
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    <description>The appeal was partly allowed with the Tribunal directing the deletion of transfer pricing adjustment based on the invalid application of the Comparable Uncontrolled Price (CUP) method and acceptance of the Transactional Net Margin Method (TNMM). The Tribunal also directed a fresh examination of the disallowed expenditure towards distribution of samples and the disallowances under sections 14A and 145A of the Act, allowing the assessee to substantiate expenses and excluding certain investments from disallowance calculation. The disallowance of club expenditure was deleted based on a previous Tribunal decision, while the disallowance under section 43B(f) was upheld following legal precedent.</description>
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      <description>The appeal was partly allowed with the Tribunal directing the deletion of transfer pricing adjustment based on the invalid application of the Comparable Uncontrolled Price (CUP) method and acceptance of the Transactional Net Margin Method (TNMM). The Tribunal also directed a fresh examination of the disallowed expenditure towards distribution of samples and the disallowances under sections 14A and 145A of the Act, allowing the assessee to substantiate expenses and excluding certain investments from disallowance calculation. The disallowance of club expenditure was deleted based on a previous Tribunal decision, while the disallowance under section 43B(f) was upheld following legal precedent.</description>
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