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Segmental results to be accepted if TPO failed to establish difference between FAR of AE & non-AE

April 24, 2019[2019] 106 taxmann.com 147 (Delhi - Trib.)
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TRANSFER PRICING: Where in respect of consultancy, project monitoring and supervisory services rendered by assessee to its AE, TPO made addition to ALP by rejecting segmental results shown by assessee, in view of fact that TPO failed to point out difference between functions performed, assets deployed and risk undertaken by assessee in its transactions with AE and non-AE customers, segmental results had to be accepted and, consequently, impugned addition was to be deleted

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