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2012 (8) TMI 191 - AT - Income TaxTransfer pricing – rejection of comparable uncontrolled price [CUP] method and determination on the basis of adjusted ALP - According to assessee it was corporate policy of AEs all over world that after payment of costs, profits were shared equally between AEs that had participated in transaction – Held that:- in the appellants own case appeal filed by the assessee was allowed and hold that the additions on account adjustment in arm's length price is uncalled for and accordingly the adjustment is rejected – Assessee’s appeal allowed
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