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2011 (1) TMI 1245 - AT - Income TaxTransfer pricing adjustment - Pre-operative expenses - Held that:- The assessee has incurred expenditure from 1.1.2004 to 14.3.2004 i.e. after entering into agreement with AE on 1.1.2004 and this amount is liable for mark up at 10% because no customer would pay mark up before entering into agreement - The expenditure incurred after agreement only has to be mark up - The Revenue has not brought any material on record to show that the assessee has incurred any expenditure before entering into service agreement on the impugned issue - Decided against Revenue.
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