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ITAT slams AO for computing ALP of international transaction on adhoc basis

August 16, 2019[2019] 107 taxmann.com 426 (Mumbai - Trib.)

TRANSFER PRICING: Where assessee-advertising agency availed different intra-group services from its foreign AEs, ALP cannot be determined by TPO in respect of said services on adhoc/estimation basis without applying any method prescribed under section 92C(1)

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