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2022 (12) TMI 420 - AT - Income TaxTP Adjustment - processing fees received on account of guarantees issued to Indian beneficiaries (based on the corresponding back-to-back guarantee provided by the overseas associated enterprises) - HELD THAT:- As respectfully following the order passed by the Co–ordinate Bench of the Tribunal in assessee’s own case cited [2022 (4) TMI 1438 - ITAT MUMBAI] we uphold the plea of the assessee and delete the impugned transfer pricing adjustment. Accordingly grounds no. 1 and 2 raised in assessee’s appeal are allowed.
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