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2013 (7) TMI 1101 - ITAT AHMEDABADExtract: .......t the addition made by the AO on account of ALP as per TPO and as per DRP is not sustainable and hence, we delete the same. Ground No.1 is allowed. Ground No.2 is regarding initiation of penalty proceedings under Section 271(1)(c) of the IT Act and this ground is rejected as premature. 6. In the result, the appeal of the assessee is partly allowed.
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