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2016 (5) TMI 40 - AT - Income TaxTransfer pricing adjustment - Held that:- The object of the TP provisions is to make adjustment if it is found that the international transactions were not at Arm’s length. The provisions were not incorporated to make adjustment at any cost and ignoring the basic facts. If the correct figure of GP margin is taken it works out to 19. 35%. The assessee’s gross margin(28. 45%) is higher than the margin of 19. 35% of the comparables. Therefore in our opinion the transaction in question is at arm’s length. We are not adjudicating the issue of total turnover versus turnover with the AE and the related issues - Decided in favour of assessee
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