DRP Supports Adjustment to Arm's Length Price; No Interference Needed, Penalty Proceedings Justification Available for Taxpayer.

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....Addition at the direction of DRP as against the total adjustment to ALP made in the draft assessment order –No any reason to interfere with the finding of the learned DRP as the assessee can very well make out a case for dropping the proceedings for imposition of penalty when the Assessing Officer actually takes up such proceedings - AT....