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Asstt. Commissioner of Income Tax, Range–10 (2) , Mubai Versus M/s. Koch Chemical Technology Group (India) Limited and Vica-Versa

2015 (11) TMI 16 - ITAT MUMBAI

Disallowance of 50% of purchase value of second hand machineries - Transfer pricing adjustment - Held that:- When the Transfer Pricing Officer has failed to refer the valuation to the DVO and on the contrary has proceeded to quantify the value of the machineries at 50% by adopting a method which is not in conformity with the statutory provisions, in our view, the matter cannot be restored back to him again for giving him a second innings. Considering the fact that 50% disallowance made out of th .....

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ment at “NIL” on the basis of certain general and sweeping observation - Held that:- Determination of arm’s length price at “NIL” without following the method prescribed under the statute is legally unsustainable. The DRP, in our view, has also upheld the determination of arm’s length price at “NIL” in a mechanical manner without proper application of mind. It is pertinent to mention here that in the immediately succeeding year i.e., assessment year 2007–08, the Transfer Pricing Officer, while c .....

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en as “NIL” and the cost incurred by the assessee on actual basis deserves to be allowed. We order accordingly. - Decided in favour of assessee.

Disallowance of depreciation on goodwill - Held that:- In view of the observations of the Co–ordinate Bench of the Tribunal in assessee’s own case for the preceding assessment year, on materially identical facts, we have no hesitation in allowing assessee’s claim of depreciation on goodwill. Insofar as the learned Departmental Representative’ .....

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t.- Decided in favour of assessee.

Enhancing the value of closing stock of raw material by the amount of unutilized CENVAT credit - Held that:- If any adjustment is required to be made in terms with section 145A, effect to the same should be given irrespective of any consequences on the computation of income for tax purposes. The Court held for giving effect to section 145A of the Act, if there is change in the closing stock of the relevant previous year, then there must necessarily b .....

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to the closing stock, then corresponding adjustment has to be made to the opening stock of raw material for the next year. In either case, it will be revenue neutral. Hence, in our view, the adjustment made by the Assessing Officer and confirmed by the learned CIT(A) is not sustainable. Accordingly, we delete the same - Decided in favour of assessee. - ITA no.8091/Mum./2011, ITA no.7236/Mum./2010, ITA no.7958/Mum./2011 - Dated:- 30-9-2015 - SHRI D. KARUNAKARA RAO, ACCOUNTANT MEMBER AND SHRI SA .....

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esolution Panel (DRP), whereas there are cross appeals filed against the order dated 12th May 2011, passed by the learned Commissioner (Appeals)-15, Mumbai, pertaining to the assessment year 2007-08. Since the facts and issues are more or less common, these appeals have been clubbed together and are being disposed of by way of this consolidated order for the sake of convenience. ITA No. 7236/Mum/2010 2. In the present appeal the assessee has raised three issues in this appeal which are as under: .....

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the arm s length price in respect of two categories of international transactions i.e., purchase of fixed assets and payment made under cost sharing agreement, we will discuss facts relevant to these two issues only. 3. As far as the first issue raised in ground Nos. 1.1 to 1.5 is concerned, briefly the facts are, the assessee an Indian company is a wholly owned subsidiary of Koch Glistsch, Mauritius, which in turn is entirely held by Koch Engineering Co. Inc., U.S.A. As stated, assessee is basi .....

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has entered into international transactions with its A.E., made a reference to the Transfer Pricing Officer for determining the arm s length price of the international transactions. In the course of proceedings before him, the Transfer Pricing Officer noticed that assessee during the year has incurred expenditure of ₹ 1,10,45,668, towards purchase of fixed assets. He found that the assessee has bench marked the transactions by adopting transaction net margin method (TNMM). The Transfer Pr .....

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ot provided the basis the basis for arriving at the valuation. He observed that on what basis the fair market value having regard to the fair market value of similar new machinery in the open market and depreciation thereon for the period of use has been taken into consideration by the valuer. Alleging that the assessee did not furnish the relevant details relating to the value of second hand machinery, he opined that an adjustment to the extent of 50% of the value of purchases of the second han .....

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st of machinery. 5. The learned Counsel for the assessee submitted before us that the assessee had purchased certain second hand machineries from its A.E. during the year. It was submitted, these machineries were acquired by the A.E. in earlier years and from the make and model of the machineries, it appears that they are of the year 1997, 1998, 2000 and 2004. He submitted that since these were acquired by the AE and used by it, the assessee, at the time of purchase, got them surveyed through a .....

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his context, the learned counsel drew our attention to the details of purchase of machineries, a copy of which is at Page-278 of the paper book. It was submitted, when the Transfer Pricing Officer is accepting the value of other machineries as per the valuation report, there is no reason why he should reject the value of two of the machineries purchased by the assessee. The learned counsel, taking us through the valuation report of the approved valuer, submitted that the report, after taking int .....

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cost of machineries is the actual market value in terms with the valuation report. He submitted that if the Transfer Pricing Officer had any reservations with regard to the valuation made by the approved valuer, then he could have referred the valuation to the Departmental Valuation Officer (DVO). The Transfer Pricing Officer not being an expert in the matter of valuation could not have disallowed 50% of the purchase price on ad-hoc basis. In this context, he relied upon a decision of ITAT, Hyd .....

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tted that the disallowance is not legally sustainable. 6. The learned Departmental Representative, on the other hand, submitted before us that in the course of proceedings before the Transfer Pricing Officer, the assessee did not furnish any details with regard to the year of purchase of the machineries by the A.E. and the depreciated value of the machineries in the books of the A.E. Moreover, the valuation report also does not indicate the basis on which approved valuer determined the value of .....

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n fixed assets i.e., machineries from third parties as well as its A.Es. It is to be observed that the assessee, during the year, placed orders with its A.E. for purchase of machineries worth U.S. $224914.84 and in terms with the purchase orders of the assessee, the A.E. supplied the machineries. It appears, out of the machineries supplied by the A.Es, which are second hand, the Transfer Pricing Officer has accepted the purchase value in respect of some machineries, whereas, in respect of two ma .....

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h evident that to substantiate the price paid for purchase of certain second hand machineries from the A.E., the assessee has produced documentary evidences including the valuation report. Whereas, the Transfer Pricing Officer, apart from making some general observations to the effect that the details of date of purchase by the A.E., depreciated value in its books are not available, has quantified the value of the two machineries at 50% of the value claimed by the assessee. On what basis he adop .....

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here being no other material brought on record by him to demonstrate that he made enquiry of any kind to ascertain the fair market value of machineries, he could not have quantified the value of the machineries at 50% of the value shown by the assessee. The DRP, in our view, has also sustained the disallowance without proper application of mind and in a mechanical manner. The Tribunal, Hyderabad Bench, in Tecumseh Products Ltd. v/s ACIT, ITA no.1686/Hyd./2010, dated 13th November 2013, while con .....

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e authorities, the comparative analysis of the machinery prepared indicates that purchase price paid to M/s TPC USA is lower than the value determined by M/s SGS Global Trade Solutions. Assessee paid customs duty and also countervailing duty and the valuation was accepted by the authorities at the time of import. Though TPO as well as DRP were of the opinion that the machinery does not have any value, we do not understand on what basis they have come to this opinion. There is no dispute with the .....

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aluation officer under the IT Act. Without doing so, the TPO or the DRP has no base to determine the value at and consequently denying the depreciation claim of the assessee while at the same time, the payment of custom duty and countervailing duty are considered as value of cost. Not only that, as submitted by Assessee and as seen from the Table furnished, new machinery worth US$ 500,965 was also treated as old machinery and valuation was determined at Nil. This shows non-application of mind by .....

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y any valuation officer that can be taken as external CUP and the value as paid by Assessee can be accepted as such. further the price paid being lesser than valuation officer s value available, the same can be accepted as ALP. iii) The learned counsel in the course of arguments relied on the decision of the coordinate bench of ITAT, Mumbai in the case of Ballast Nedam Dredging in ITA Nos. 6531/Mum/06 & 1591/Mum/08, order dated 31-01-2013 to submit that in the absence of any contrary certifi .....

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s external CUP. Under both the workings Assessee is able to justify the price paid and on this reason also, we have to accept Assessee s contentions. Similarly, in the case under consideration, Assessee justified the price paid by way of a certificate which can be considered as external CUP. Since TPO/DRP did not rely on any other certificate and in the absence of any contrary information, price paid by Assessee, which was lesser than the value mentioned in the certificate can be accepted as suc .....

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was incumbent upon the TPO to determine the ALP by applying any one of the method as prescribed under section 92C(1)(a) to (e). In the present case, admittedly the assessee has benchmarked the transaction with AE by applying TNMM. On carefully going through the order of TPO it appears, he has not rejected TNMM as most appropriate method. In fact, TPO is totally silent on what method he has adopted for determining the ALP of international transaction relating to purchase of machineries. TPO has n .....

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However, we are unable to accept such contention of the learned Departmental Representative for the simple reason that when the Transfer Pricing Officer has failed to refer the valuation to the DVO and on the contrary has proceeded to quantify the value of the machineries at 50% by adopting a method which is not in conformity with the statutory provisions, in our view, the matter cannot be restored back to him again for giving him a second innings. Considering the fact that 50% disallowance made .....

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as paid amounts of ₹ 33,72,714, and ₹ 8,21,370 on account of cost sharing arrangement towards information technology, commercial, finance, legal and administrative support. It was submitted, the assessee has entered into cost sharing agreement with the A.E. which is common for the entire group and the A.E. was reimbursed the cost on actual basis. The Transfer Pricing Officer observed, though, the assessee was called upon to furnish details and evidences to establish receipt of servic .....

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o added the amounts of ₹ 33,72,214 and ₹ 8,21,370, to assessee s income of the year. The DRP also sustained the addition made on account of determination of arm s length price at NIL by more or less adopting the view expressed by the Transfer Pricing Officer. 9. The learned Counsel for the assessee submitted, the A.E. incurred certain common cost in respect of all the companies in the Group for providing various support service including commercial cervices, financial services, admin .....

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oviding support services. He also drew our attention to the nature of services provided by the A.E. as well as the invoices raised for the services rendered. The learned counsel also drew our attention to certain e-mail exchanged between the assessee and the A.E. in relation to the services availed and cost incurred. The learned counsel submitted, all the details relating to cost sharing agreement were submitted before the Transfer Pricing Officer and ignoring those evidences, he could not have .....

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by the Commissioner (Appeals). 10. The learned Departmental Representative, on the other hand, justifying the determination of arm s length price at NIL submitted that the issue which requires to be looked into is whether there was at all a necessity for cost sharing. He submitted, the assessee also was required to establish through proper documentary evidences whether the A.E. had actually rendered services and the assessee has actually availed of such services. He submitted, since the assesse .....

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ort services. He also does not dispute the fact that the cost recovered by the A.E. towards services rendered to all the group companies including the assessee was on actual basis without any mark-up. It is also not in dispute that the assessee has made payments to the A.E. in terms with the cost sharing agreement. That being the case, we fail to understand as to how the Transfer Pricing Officer can determine the arm s length price of the cost sharing arrangement at NIL on the basis of certain g .....

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the matter, the Transfer Pricing Officer, as per the provisions of section 92C, has to determine the arm s length price by adopting any one of the modes prescribed therein. However, in the present case, the order passed by the Transfer Pricing Officer, in no manner, indicate the specific method adopted by the Transfer Pricing Officer to determine the arm s length price. That being the case, the determination of arm s length price at NIL without following the method prescribed under the statute i .....

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itself shows that the Transfer Pricing Officer accepts the fact that the A.E. has provided certain services to the assessee and the assessee has availed such services. In view of the aforesaid, we hold that the determination of arm s length price of the cost sharing arrangement and I.T. support cannot be taken as NIL and the cost incurred by the assessee on actual basis deserves to be allowed. We order accordingly. Thus, the second issue raised by the assessee is decided in assessee s favour. 12 .....

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tion of ₹ 72,47,405. He, therefore, called upon the assessee to explain as to why depreciation claimed on goodwill should not be disallowed. Though the assessee on 24th August 2009, submitted a detail explanation stating therein the reasons for which the claim of depreciation should be allowed but the Assessing Officer referring to the provisions contained under Explanation 3(b) of section 32 of the Act, observed that the term Intangible Asset , has not been defined but merely enumerates c .....

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enumerated in Explanation 3(b) to section 32, which are considered to be tools of business. He observed, as goodwill is not at all a right it is not eligible for depreciation. Accordingly, he disallowed the claim of depreciation of ₹ 72,47,405. 13. The assessee challenged the disallowance before the DRP. The DRP observing that the Commissioner (Appeals) in the preceding years, have disallowed depreciation on goodwill upheld the disallowance. In terms with the orders passed by the DRP, the .....

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ubmitted, the issue whether goodwill is an intangible asset and depreciation is allowable on goodwill has also been decided by the Hon ble Supreme Court in CIT v/s SMIFS Securities Ltd., [2012] 348 ITR 302 (SC). 15. The learned Departmental Representative, on the other hand, strenuously submitted before us, goodwill cannot be considered to be a business or commercial right of the nature envisaged under Explanation-3(b) to section 32 of the Act. He submitted, the commercial rights which can be co .....

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, the learned Departmental Representative relied upon the decision of the Hon ble Supreme Court in Techno Shares and Stocks Ltd. v/s CIT, [2010] 327 ITR 323 (SC). 16. We have considered rival submissions and perused the material available on record. As could be seen, depreciation on goodwill has been disallowed by the Assessing Officer basically for the reason that goodwill has not been included as an intangible asset under section 32 of the Act. The DRP has upheld the disallowance by observing .....

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ll by holding as under:- 31. In the absence of any distinguishing feature brought on record by the Revenue, we respectfully following the above ITA No.6908/Mum/2010 25 Cross-Objection No.198/M/ 2011 ITA No.6499/Mum/2010) judgments and the consistent view of the Tribunal hold that since the assessee has made the payment for acquiring the business and commercial rights, it was comparable with the trademark, copyrights etc. referred to in the first part of clause (ii) of section 32(1) and so much s .....

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ion on goodwill. Insofar as the learned Departmental Representative s contention that goodwill having not been specifically included in Explanation 3(b) to section 32 of the Act, depreciation is not allowable, we have to observe, the issue is no more res integra in view of the Hon ble Supreme Court s decision in SMIFS Securities Ltd. (supra), wherein in no uncertain terms it has been held that goodwill being in the nature of any other business or commercial rights is an intangible asset under Ex .....

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ear 2007-08. 20. In this appeal, the assessee has raised in total five grounds. Ground no.1, reads as follows:- The learned CIT(A) erred in fact and in law in confirming the action of the Assessing Officer in disallowing depreciation on intangibles amounting to ₹ 54,35,554. 21. Briefly stated the facts are, assessee, on 24th October 1999, had acquired a running business from Topack Industries Ltd., for a total consideration of ₹ 15,77,34,000. Out of the said amount, the assessee appo .....

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t similar disallowance made in the assessment year 2005-06, was confirmed by his predecessor-in-office. 23. We have considered the rival submissions and have perused the material available on record. The facts and issue involved in this ground raised by the assessee are materially identical to ground no.3 raised by the assessee in ITA no.7236/Mum./2010, for the assessment year 2006-07. Following our detailed reasoning given in Paragraph-16 and 17 (supra) therein, we allow assessee s claim of dep .....

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he opening stock of raw material for A.Y. 2008-09 by the amount added in the closing stock of raw material of the current year. 25. Briefly stated the facts are, in the course of assessment proceedings, the Assessing Officer found that the assessee has not adjusted his closing stock by including the amount of CENVAT credit in terms of section 145A of the Act. He, therefore, called upon the assessee to explain as to why the difference of such credit amounting to ₹ 1,17,72,672, as on 31st Ma .....

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ready offered CENVAT credit to tax by claiming depreciation at reduced value of capital goods, no addition need be made in respect of unutilized CENVAT shown under the head loans and advances . Insofar as unutilized CENVAT on raw material is concerned, it was submitted, the assessee has already offered such unutilized CENVAT credit to tax by reducing the said amount from the cost of total purchase debited to the Profit & Loss account. Thus, it was submitted that as purchases are accounted ne .....

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on the taxable profit of the assessee. If the value of unutilized CENVAT credit is added in the closing stock, corresponding increase is required to be made in the purchases as the assessee has accounted for the purchases in the books of account net of CENVAT credit. The Assessing Officer, however, was not convinced with the explanation of the assessee. He was of the view, the raw materials, finished goods or semi finished goods will have to be valued after taking into consideration CENVAT relat .....

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ew expressed by the Assessing Officer. 26. We have considered the rival submissions and have perused the orders of the authorities below and the material available on record. As could be seen, during the assessment proceedings, the Assessing Officer proposed to make adjustment of unutilized CENVAT credit both in respect of purchase of raw material as well as purchase of capital goods. It was the contention of the assessee before the Assessing Officer that it is following the exclusive method of .....

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ning stock in the next year. Hence, in either case, it will be revenue neutral. On a perusal of the assessment order, it is seen that as far as adjustment of CENVAT credit on purchase of capital goods is concerned, the Assessing Officer has accepted assessee s explanation and no adjustment has been made to the closing stock. However, as far as raw material is concerned, the Assessing Officer has added the difference of CENVAT credit as on 31st March 2007 and 1st April 2006, amounting to ₹ .....

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but as held by the Hon ble Delhi High Court in CIT v/s Mahavir Aluminum Ltd., [2008] 297 ITR 77 (Del.), whenever any adjustment is made in the valuation of inventory, it will affect both the opening stock and closing stock. If any adjustment is required to be made in terms with section 145A, effect to the same should be given irrespective of any consequences on the computation of income for tax purposes. The Court held for giving effect to section 145A of the Act, if there is change in the clos .....

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d to make adjustment to the closing stock only by including the unutilised CENVAT credit. On the flip side, if adjustment is made to the closing stock, then corresponding adjustment has to be made to the opening stock of raw material for the next year. In either case, it will be revenue neutral. Hence, in our view, the adjustment of ₹ 1,04,59,372, made by the Assessing Officer and confirmed by the learned CIT(A) is not sustainable. Accordingly, we delete the same. Ground raised by the asse .....

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t. 30. This ground being pre-mature is not maintainable before us. Hence, the ground raised by the assessee is dismissed. 31. In the result, assessee s appeal for the assessment year 2007-08 is partly allowed. 32. We now take up Revenue s appeal in ITA no.8091/Mum./2011, for the assessment year 2007-08. The effective grounds raised by the Revenue are as under:- 1. On the facts and in the circumstances of the case and in law the learned CIT(A) erred in deleting the adjustment of ₹ 24,95,977 .....

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ost sharing arrangement and in respect of payment for information technology support services. 33. In ground no.1, the Revenue has challenged the decision of the learned Commissioner (Appeals) in deleting the addition made of ₹ 24,95,977, on account of adjustment to the arm s length price of international transaction involving purchase of machinery from the A.E. 34. Briefly stated the facts are, during the relevant previous year, assessee had purchased second hand machinery from its A.E. w .....

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t the value determined by him is the fair market value of the machinery having regard to the fair market value of similar new machinery in the open market after excluding depreciation thereof for the period of use. Accordingly, he disallowed 50% of the value declared by the assessee and determined the arm s length price of the transaction at ₹ 24,95,976. In terms of the order passed by the Transfer Pricing Officer, the Assessing Officer completed the assessment by making disallowance of an .....

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the basis for arriving at the valuation is not provided; ii) The Transfer Pricing Officer has not given any reason for adopting the arm s length price @ 50% of the value of the international transaction on ad-hoc basis; and iii) The Transfer Pricing Officer has not determined the arm s length price by following any of the methods prescribed in the statute. 36. We have considered the rival submissions and have perused the material available on record. The aforesaid issue is materially identical .....

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learned Commissioner (Appeals) on this issue. Ground no.1 is thus dismissed. 37. Ground no.2, raised by the Revenue relates to the decision of learned CIT(A) in deleting the addition of ₹ 3,88,155, being adjustment made to the arm s length price of the international transaction relating to cost sharing arrangement and I.T. support services. 38. Briefly stated the facts are, in the course of proceedings before him, the Transfer Pricing Officer found that the assessee has entered into intern .....

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d, the Transfer Pricing Officer disallowed an amount of 20% out of the amount paid by the assessee to its A.E. on cost sharing arrangement. As a result, an adjustment of ₹ 3,88,155, was made to the arm s length price. 39. Being aggrieved of such adjustments, the assessee challenged the same before the learned Commissioner (Appeals). The learned Commissioner (Appeals) deleted the addition by observing that the Transfer Pricing Officer has not been able to point out any specific defect or de .....

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