TMI Blog2016 (2) TMI 1100X X X X Extracts X X X X X X X X Extracts X X X X ..... d on which the AO rejected the CUP method adopted by the Assessee was that “the price charged or paid” was on the basis of a broker quote, though based on the prices prevailing in the market, and was not a price charged or paid because it did not reflect the price of an actual transaction. As noted by the ITAT, Rule 10 D (3) (c) of the Income Tax Rules, 1962 envisages that the TPO should take i ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 2. The ground sought to be urged by the Revenue is whether the ITAT was justified in deleting the addition of ₹ 29,70.31,153 made by the Assessing Officer ( AO ) in terms of the order of the Transfer Pricing Officer ( TPO ) in relation to the arm s length price of its international transaction pertaining to the import of edible oil from the Assessee s associated enterprise by using the Com ..... X X X X Extracts X X X X X X X X Extracts X X X X
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