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    <title>2023 (1) TMI 658 - ITAT DELHI</title>
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    <description>The Tribunal partially allowed the assessee&#039;s appeal, focusing on transfer pricing adjustments and the determination of international transactions for AMP expenditure. The adjustments made by the Transfer Pricing Officer were deemed unsustainable, leading to their deletion. The Tribunal emphasized consistency in decisions and adherence to legal provisions in transfer pricing assessments, directing further evaluation by the TPO on specific aspects for statistical purposes. The issues of penalty proceedings initiation and interest levied were not extensively discussed, indicating they were likely dismissed without significant consideration.</description>
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