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    <title>2021 (2) TMI 1332 - ITAT DELHI</title>
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    <description>The assessee was characterised as providing sales and marketing support services in the nature of coordination support, not as an advertisement and marketing agency. Because that functional profile was central to benchmarking, the transfer pricing adjustment and the selection and rejection of comparables could not be conclusively sustained on the existing analysis. The ITAT therefore remanded the transfer pricing issue and connected grounds to the Transfer Pricing Officer and Assessing Officer for fresh consideration, with a proper opportunity of hearing to the assessee in line with natural justice. The appeal was partly allowed for statistical purposes.</description>
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      <link>https://www.taxtmi.com/caselaws?id=306496</link>
      <description>The assessee was characterised as providing sales and marketing support services in the nature of coordination support, not as an advertisement and marketing agency. Because that functional profile was central to benchmarking, the transfer pricing adjustment and the selection and rejection of comparables could not be conclusively sustained on the existing analysis. The ITAT therefore remanded the transfer pricing issue and connected grounds to the Transfer Pricing Officer and Assessing Officer for fresh consideration, with a proper opportunity of hearing to the assessee in line with natural justice. The appeal was partly allowed for statistical purposes.</description>
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