Transfer Pricing Officer's Error: Incorrectly Increased Operating Costs by Including Reimbursements, Leading to Double Addition.
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....TP adjustment - TPO while working out the operating cost has made an addition of reimbursement received on account of advertisement and warranty - it is apparent that the adjustment made by the learned TPO by increasing the operating expenses by this amount is erroneous and incorrect - it amounts to double addition....
TaxTMI