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TPA - it is since the parameters laid down in sub-section (1) are not fulfilled, there is no...

TPA - it is since the parameters laid down in sub-section (1) are not fulfilled, there is no relationship of AE between assessee-company and JII and therefore, the provisions of chapter X of the Act have no application. In the result, the transfer pricing adjustment made by the TPO is not valid in law. - AT .....

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