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2015 (2) TMI 1118 - AT - Income TaxTransfer pricing adjustment - upward adjustment holding international transactions relating to the issuance of equity shares entered into by the assessee with its Associated Enterprises (AE) were not at Arm's Length - Held that:- Considering the undisputed issue of the capital nature of the transaction in question, we are of the opinion that the adjustments made by the TPO are outside the scope of the TP provisions. We accordingly allow the issue raised by the assessee in its favour
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