2026 (3) TMI 1495

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....ent : Sh. Dharm Veer Singh, CIT(DR) ORDER PER ANUBHAV SHARMA, JM: This appeal is preferred by the assessee against the order dated 11.01.2023 of the Ld. Commissioner of Income Tax (A)-44, Delhi (hereinafter referred as Ld. First Appellate Authority or in short Ld. 'FAA') in DIN : ITBA/APL/S/250/2022-23/1048635090(1) arising out of the order dated 31.01.2020 u/s 143(3) r.w.s 254 of the Inc....

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....uent development of law is cited to show and to assert that ld. CIT(A) was not justified in relying upon the decisions in the case of assessee itself. 4. The issue revolves around the transfer pricing adjustments made on alleged international transaction involving AMP expenses. Admittedly, in AY: 2011-12 which is preceding assessment year vide ITA No. 1611/Del/2016 order dated 11.06.2019 Coordi....