TPO's Rejection of Segmental Approach Overturned; Expenses for Outbound Engineering Services Deemed Commercially Justified.

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....TP Adjustment - Engineering services and Administrative Support services - TPO has rejected the segmental approach adopted by the assessee for benchmarking its international transactions pertaining to provision of outbound engineering services - There is absolutely no doubt that the impugned expenditure has been incurred for the purposes of assessee’s business carried on by the assessee and that it was commercially expedient as well. - Addition deleted - AT....