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Section 44BBB Inapplicable: Additions Against Domestic Companies Unjustified; Assessing Officer Failed to Justify Loss Disallowance and Transfer Pricing.
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....Applicability of provisions of Section 44BBB - Once the provisions and Section 44BBB are not applicable to domestic company, there were no justification even to place reliance upon the said provision while making the addition against the assessee - A.O. has neither given reasons as to why the losses incurred by the assessee are not allowable nor the applicability of provisions of transfer pricing - addition not sustainable....