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2011 (7) TMI 315 - ITAT BANGALOREArm Length Price (ALP) - transfer pricing adjustment made by determining the ALP - The assessee has approached DRP only against the order of the TPO and it is the duty of the DRP to consider the assessee's objections to the TPO orders in judicious way. By summarily accepting the order of the TPO, the DRP has failed to perform the duty entrusted to it. However, since the TPO has not dealt with the objections raised by the assessee against the comparables selected by the TPO, we deem it fit and proper to remit the issue to the file of the assessing authority for taking necessary action of making a reference to the TPO to deal with the assessee's objections and for passing a speaking order. determination of Arm Length Price (ALP) by Transfer Pricing Officer (TPO) -
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