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2022 (9) TMI 1438 - ITAT PUNETP Adjustment - ALP adjustment pertaining to its receipts of corporate support services - HELD THAT:- The same admittedly appears a recurring issue between the parties therefore. This tribunal’s learned co-ordinate benches have been reversing the department’s view questioning the impugned corporate support services received from the overseas associate enterprises “AE” namely M/s. Eaton (China) Investments Co. Ltd. at cost + mark up of 9% and from Eaton Hydraulics LLC on cost to cost basis ; respectively. The Revenue could not pin-point any distinction on facts or law in all these assessment years; as the case may be.
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