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Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for ALP determination
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....ITAT upheld that the TPO's substitution of projected figures with actuals in valuation of specified assets was unwarranted; the original acquisition valuation, supported by board resolution and independent valuer, must stand and the TPO cannot rework projections against actual performance. TP adjustments regarding support services, R&D services comparables, and selection of the most appropriate method were remitted to AO/TPO for de novo determination of ALP, benchmarking and FAR-based comparable selection; AO/TPO to apply MAM/TNMM/RPM as appropriate, give the assessee opportunity of hearing, and consider submission of AE cost data, allocation keys and working capital adjustments. The remitted grounds are allowed for statistical purposes.....