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2015 (4) TMI 1239
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....ondent : Mr. Ajay Vohra, Sr. Adv. with Ms. Kavita Jha and Mr. Vaibhav Kulkarni, Advs. O R D E R 1. Admit. 2. Ms. Kavita Jha, Advocate accepts notice. 3. The following question of law arises for consideration : "Whether on facts and circumstances of the case, the Hon'ble ITAT has erred in holding that new unit is to be treated as a separate and independent unit for the purp....
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....th respect to the profits margin derived by the assessee in regard to its transactions with the associated enterprise could have been subjected to adjustment. The ITAT was of the opinion that since the assessee was a service provider to its associated enterprise (AE) as well as other foreign customers or non- AEs, the suggestion that the non- AE transactions which reported lower margins and to be ....