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of <h1>Assessee Appeals on Arm's Length Price Determination Under Income Tax Act, 1961; Tribunal Highlights Transfer Pricing Complexities.</h1> The case involves an appeal by an assessee challenging the Commissioner of Income Tax (Appeals) regarding the determination of Arm's Length Price (ALP) under the Income Tax Act, 1961, focusing on transfer pricing. Key issues include the correct application of the arm's length principle for international transactions, the admissibility of additional evidence, changes in benchmarking approaches over different assessment years, and discrepancies in the functional profile and selection of comparable companies. The Tribunal's decision emphasizes the complexities of transfer pricing, the importance of procedural fairness, and the need for consistency in transfer pricing documentation.
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