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Assessing Officer's Arm's-Length Price for Project Fees Incorrect; Transfer-Pricing Officer's Zero Valuation Overturned.
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....TP Adjustment - specified domestic transaction of project management and supervision - Capitalized expenditure - AO is incorrect in determining the arm’s-length price of specified domestic transaction after omission of clause (i) of Section 92BA - the action of the learned transfer-pricing officer in determining the arm’s-length price of project management and supervision fees at Rs Nil and consequent disallowance of depreciation there on is not correct. - AT....