Support Service Charges Disallowed Due to Lack of Evidence; Chapter X Provisions Take Precedence Over General Income Tax Rules.

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....TP Adjustment - Disallowance of support service charges to ultimate holding company in absence of evidence of service availed - once the transaction is undisputedly subject matter of chapter X 'Special Provisions relating to Avoidance of Tax' of the Act, then other general provisions of the Act cannot be applied simultaneously. - AT....