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2022 (12) TMI 1204 - ITAT MUMBAITP Adjustment - determination of the arm’s length price of ‘deemed international transactions’ of television content production fees received from the broadcasters - HELD THAT:- For determination of arm’s length price of the deemed international transactions, it is important to go through the agreement entered between the AE and domestic third-party. The said agreement and confirmation have been filed for first time before us, which being crucial and important for adjudicating the issue dispute, same are admitted as additional evidence in terms of Rule 29 of ITAT Rules, 1963 and issue-in-dispute involved in relation to adjustment to the deemed international transactions is restored back to the file of the Ld. AO/TPO for deciding afresh after providing adequate opportunity of being heard to the assessee. The ground of the appeal of the assessee accordingly allowed for statistical purposes.
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