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Assessing Officer's Unscientific Method for Arm's Length Price Leads to Incorrect Transfer Pricing Adjustment, Dismissing Valid Quotations.
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....Transfer pricing adjustment - determining ALP - Assessing Officer was thus in error not only in resorting to an unscientific and unrecognized method ascertaining the arm’s length price of the services rendered by the assessee but also in rejecting bonafide quotations as a valid input for ascertaining the arm’s length price by the assessee. - AT....