Dispute on 8% Markup in Transfer Pricing for Capital Goods Purchase Remanded to DRP for Arm's Length Price Assessment.

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....TP Adjustment - international transaction pertaining to purchase of capital goods from AE - the issue of allowability or not of the markup of 8% charged by the AE has not been determined as per the approved methods, we hereby deem it fit to remand the matter to the file of the ld. DRP to determine the ALP as per the approved methods after giving an opportunity to the assessee to make their submissions. - AT....