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2018 (4) TMI 1579 - AT - Income TaxTransfer pricing - determination of Arms Length Price - Profit Split Method - absolute sale of intangible asset to AE - Held that:- there is no international transaction during the relevant financial year - no adjustment is required - Decided in favor of assessee. Commercial wisdom of the appellant' decision to incur the expenditure towards management consultancy fees - This issue is also covered in favor of assessee in earlier decisions - Appeal of the assessee allowed.
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