2024 (3) TMI 1443

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....Bhatia, SSC withMs. Deeksha Gupta, Adv. For the Respondent : Mr. Ajay Vohra, Sr. Adv. With Mr. Samarth Chaudhari, Adv. ORDER 1. We take note of the contention of Mr. Bhatia, learned counsel appearing for the appellants, who draws our attention to the following extracts from the order of the Transfer Pricing Officer ["TPO"]: " Moreover, it is seen from the details contained in the....

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.... would agree to incur expenditure without independently ascertaining the value of the goods/ services intended to be availed, in the market and that too at the best negotiated prices. No such effort has been demonstrated to be made at the end of the assessee, which weighs heavily against the normal practises of business prudence." 2. It is in the aforesaid backdrop that Mr. Bhatia contends that....