CIT (Appeals) Rejects Entity-Level Profit Margin; Reassesses ALP for International Transactions Under Transfer Pricing Rules.

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....Transfer pricing adjustment - determination of ALP - Once the CIT (Appeals) has rejected the entity level profit margin of the assessee for the purpose of bench marking the international transactions with ALP, the CIT (Appeals) was required to redo exercise of determination of ALP as per the provisions of transfer pricing - AT....