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    <title>2025 (10) TMI 300 - ITAT MUMBAI</title>
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    <description>ITAT MUMBAI - AT allowed the appeal against TP adjustments for AMP expenses, holding there was no international transaction and the Revenue failed to prove otherwise; Chapter X provisions and TPO adjustments were not invocable, and earlier Tribunal precedent in favour of the assessee was followed. Grounds challenging the AMP-related adjustments were allowed. On foreign tax credit, the assessee had filed an application under s.154 seeking correction and relief; the A.O. was directed to consider that s.154 application and pass a reasoned order.</description>
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      <title>2025 (10) TMI 300 - ITAT MUMBAI</title>
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      <description>ITAT MUMBAI - AT allowed the appeal against TP adjustments for AMP expenses, holding there was no international transaction and the Revenue failed to prove otherwise; Chapter X provisions and TPO adjustments were not invocable, and earlier Tribunal precedent in favour of the assessee was followed. Grounds challenging the AMP-related adjustments were allowed. On foreign tax credit, the assessee had filed an application under s.154 seeking correction and relief; the A.O. was directed to consider that s.154 application and pass a reasoned order.</description>
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