Assessing Officer's Profit Conversion Based on CBDT Draft Report Overturned; Losses Restored for 2018-2020 Fiscal Years.

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....Dependent agency PE of the assessee in India - profit attribution to the said DAPE - TP adjustments - Arm's length price - it has been brought on record that assessee had incurred losses in the fiscal year 2018, 2019 and 2020 and ld. AO without analyzing the transactions had made the losses of the assessee into profit just merely rely on the draft report of the CBDT and a recommendary course of action for the profit attribution to the PE. - Additions deleted - AT....