2018 (6) TMI 1866

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....e Respondent : Mr. Siddharth Das, Adv. ORDER The Court : No question of law is raised in the proposed appeal, but the Revenue asserts that the Commissioner (Appeals) erred in providing for deductions despite the Transfer Pricing Officer finding that the payments made by the assessee to its Canadian associate were not against any services received from such associate but a colourable way of d....

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.... passed by the Appellate Tribunal. The Appellate Tribunal questioned the basis of the opinion rendered by the TPO that such services were rendered uniformly to all associate concerns by the concerned associate of the assessee in the present case. The Appellate Tribunal found that the TPO had not rendered a finding that such services were rendered by the entity to all associates without obtaining a....