TMI Blog2022 (5) TMI 1502X X X X Extracts X X X X X X X X Extracts X X X X ..... mpractical and absurd since no customer will be willing to pay an additional price for the same product / service even in an arms' length transactions, merely because the business is acquired by another party who is continuing to offer the same product / service. He referred to the illustration of the Case Law Compilation. Inclusion of comparable companies - We remit this issue to AO/TPO to include the comparables, if the comparables are not incurring the losses continuously in 2 out of 3 assessment years. Ordered accordingly. Inclusion of companies accepted by the DRP - In our opinion, the AO is bound by the directions of DRP and he has to pass the final assessment order in conformity with the directions of the DRP. Ordered accordingly. Working capital adjustment for determining the ALP - The assessee in the present case has given all the details required for working capital adjustment. Therefore, the Revenue Authorities were not justified in denying the claim of the assessee for deduction. AO / TPO is directed to allow the working capital adjustment in the light of the material placed on record, after affording a reasonable opportunity of hearing to the assesse ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... the department. Therefore, the Valuation report in question cannot be relied upon and as such is liable for rejection. We have heard both the parties and perused the material on record. Similar issue came for consideration before the Delhi Tribunal in the case of Rockland Diagnostics Services P. Ltd [ 2021 (3) TMI 17 - ITAT DELHI] As held by the Co-ordinate Bench of the Tribunal that in absence of any specific inaccuracies or short comings in the DCF valuation report other than stating that yearwise results as projected are not matching with the actual results declared in the final accounts, the Assessing Officer cannot substitute his own value in place of the value determined either on DCF method or NAV method. Therefore, we are of the considered opinion that the Lower Authorities were not justified in rejecting the valuation report as submitted by the assessee in this regard. We also note that the observation of the Ld. CIT (A) that the Chartered Accountant has relied on the data supplied by the assessee in this regard is irrelevant in as much as the Chartered Accountant has carried out the valuation in accordance with the prescribed method as per Rule-11UA of the Income T ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... a payment the made by an acquirer (the Appellant) in anticipation of future economic benefits. These benefits are not immediate but generally accrued over a period of time. 6. It is submitted that the said goodwill as an intangible asset, was not recorded or recognised by the Transferor, i.e., TECGSS, prior to the said acquisition but arose pursuant to the acquisition on account of the significant premium paid for the business. It is therefore a cost associated with the purchase of the business and it is not a tool deployed in business. Unlike assets such as plant and machinery, office equipment, computers, laboratory equipment, etc., which are purchased and used for undertaking the normal day-to-day operations, goodwill is the price paid for acquiring an on-going business. The same is amortized/ impaired in the books of account, over a period as required by the accounting standards, and such period does not necessarily coincide with the actual period over which the business will reap benefits from such payment. Hence, the purchase of goodwill cannot be equated to other capital assets used for running the business. 7. He submitted that the ability of the business to genera ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... guidelines cm transfer pricing, as summarized below:- The Rule 10C(2)(e) of the Income-tax Rules, 1962 ( the Rules ) states that in selecting the most appropriate method, the extent to which reliable and accurate adjustments can be made to account for differences, if any, between the international transaction and the comparable uncontrolled transaction or between the enterprises entering into such transactions must be taken into consideration. Reliance is also placed on para 2.75 of the OECD TP Guidelines 2010, which states as follows: 2.75 Another important aspect of comparability is measurement consistency. The net profit indicators must be measured consistently between the associated enterprise and the independent enterprise... 11. Further reliance is placed on the following decisions, which uphold the comparability principles to be adopted for the purpose of benchmarking, in support of exclusion of amortization of G/W from the operating cost for benchmarking:- Rakhra Technologies (P.) Ltd., 347 ITR 484 (P H) B.A. Continuum India Pvt Ltd. ITA 440 of 2014 (Telangana) ICON Clinical Research India ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... oduct / service. He referred to the illustration in Pg. 629 of the Case Law Compilation. Business Activity remains constant pre and post the acquisition: 15. The ld. AR submitted that the margin computation by the Appellant, by excluding the amortisation from the operating costs is in line with the manner of benchmarking that was undertaken for such business when considered independently or prior its acquisition. When the ALP of the revenue generated by a business is determined at a stated range, when considered independently and in the absence of any acquisition, the same ought to be accepted even post acquisition if the same business activity continues as it was earlier. 16. In this regard, he relied on the following decisions, wherein the principle that a similar transaction undertaken by another taxpayer in the past would serve as a benchmark for the said transaction being carried out by the Appellant in the succeeding years, in the absence of any factual differences. Applying this principle, the transaction tested in the case of the Appellant is the revenue from rendering ITES. This transaction was undertaken by the TECGSSIPL prior to acquisition of the said busi ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... India Private Limited [erstwhile T11 Connectivity Global Shared Services India Private Limited ('TECGSS')] that supported the business operations (excluding Broadband Network Solutions segment) of TB Group. The business was, purchased on slump sale basis for an amount or INR 68.55 crores and according to the assessee, the goodwill has arisen out of such purchase consideration paid. Amortization of goodwill amounting to INR 9,13,71,302 was charged to P L account. 21. The ld. DR further submitted that amortization of goodwill is the process of expensing the cost of a goodwill over the projected life of the asset for tax or accounting purposes. The intangible assets, such as goodwill, patents and trademarks are amortized into an expense account whereas tangible assets are instead written off through depreciation. For tax purposes, the cost basis of an intangible asset is amortized over a specific number of years, regardless of the actual useful life of the asset, In the years in which the asset is either acquired and sold, the amount of amortization deductible for tax purposes is pro-rated on a monthly basis, Intangible assets are non-physical assets that can be assigned a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... milar issue came for consideration before in IT(TP)A No.713/Bang/2017 dated 24.11.2021 wherein it was held as under:- 45. We have heard both the parties and perused the material on record on this issue. This issue was considered by the Tribunal in the case of ST-Ericsson India Pvt. Ltd. v. DCIT in IT(TP)A No.609 168/Del/2015 dated 3.7.2018 and it was observed as follows:- 15. Assessee has challenged the findings returned by TPO/DRP treating amortization of goodwill as not extra ordinary in nature. It is the case of the assessee that goodwill is on account of acquisition of units through slump sale under Business Transfer Agreement and in these circumstances, amortization of goodwill is an extra ordinary item and is not pertaining to the regular operation of the taxpayer, hence non-operating in nature. 16. Ld. AR for the assessee contended that ld. DRP in assessee's own case in AYs 2011-12 and 2012-13 and ld. TPO in AY 2013-14 ITA No.168/Del./2015 has already amortized goodwill as extra ordinary in nature by excluding the same by computing operating margin of the taxpayer and order thereof is available at pages 2681 to 2695, 2696 to 2713 and 2718 and 2764 of the pap ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ations, that have a direct impact on the profitability. Reliance in this regard is also placed on the following judicial precedents, including the decisions rendered by this Hon'ble Tribunal, wherein the application of an upper turnover filter of INR 200 crores as an appropriate filter:- Pentair Water India Pvt Ltd., TS-566-HC-2015 Fulcrum Fund Services (India) Pvt Ltd., IT(TP)A No.2521/Bang/2017 Autodesk India Pvt Ltd., TS-62-ITAT-2013 Cenduit India Services Pvt Ltd., TS-19-ITAT-2022 Software Paradigms Infotech Pvt. Ltd., TS-676-ITAT-2021 Entercoms Solutions Pvt Ltd. TS-548-ITAT-2021 27. The ld. DR submitted that some of the comparables selected by the TPO are challenged on grounds of size and level of operations and also on account of its high profit margins. With regard to the issue of high/low turnover, the Department's stand has consistently been that turnover is not a relevant filter in the software industry. In the software, industry size has no influence on the margins earned by the company. Economies of scale are re ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... (3) Mindtree Ltd. 590.39 crores (4) Persistent Systems Ltd. 293.74 crores (5) Sasken Communication Technologies Ltd. 343.57 crores (6) Tata Elxsi Ltd. 262.58 crores (7) Wipro Ltd. 961.09 crores. (8) Infosys Technologies Ltd. 13149 crores. 29. Accordingly, we direct the AO/TPO to consider the comparability of the companies in terms of the above order of the Tribunal and decide the issue. 30. Ground Nos. 2.8 and 2.9 read as under:- The DRP erred in : 2.8 Including the following companies even though such companies are functionally different (such as engaged in KPO activities, diversified activities with no segmentation, extra ordinary event, etc.) from the Appellant: Tech Mahindra Business Services Limited; Infosys BPM Limited; and SPI Technologies India Private Limited. 2.9 Excluding Ace BPO Services Pvt Ltd even though the same is functionally ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... 4. Capgemini Solutions Ltd. 297 35. Reliance was placed on the decision of Hyderabad ITAT in Infor India Pvt. Ltd., TS-499-ITAT -2021 wherein for the same assessment year, i.e., AY 2016-17, the Tribunal held that the said companies (S.No. 1 to 3) ought to be excluded in view of their high turnover of over INR 200 Crores. The same ratio would be applicable to the company at S.No. 4 above. 36. As discussed in para 28, this issue is remitted to the AO/TPO with similar directions. Inclusion of comparable companies 37. The ld. AR submitted that the. TPO erroneously excluded Ace BPO Services Pvt. Ltd. on the sole ground that it is a 'persistent loss-making company'. In this regard, it is submitted that said company incurred a loss only for FY relevant to the Impugned AY, but recorded profits during the preceding two FYs (i.e., FY 2013-14 and 2014-15) and therefore cannot be considered as a persistent loss-making company. 38. He submitted that it has been settled by several jurisprudence on the subject, that incurrence of loss in a single year cannot be the basis for considering the said company as a ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tems (P.) Ltd. (supra) supports the assessee's counsel arguments. Being so, for proper comparables these three companies viz., items at 11, 13 and 14 are to be included in the comparables if their loss is on account of normal business reasons and segmental turnover is above Rs. 1 crore. This view of ours is also supported by the order of the Tribunal Delhi Bench in the case of Sapient Corporation (P.) Ltd. v. Dy. CIT [2011] 46 SOT 56/11 taxmann.com 69, Genisys Integrating Systems India (P.) Ltd. v. Dy. CIT [2012] 53 SOT 159/20 taxmann.com 715 (Bang.) wherein held that when companies which are loss making are excluded from comparables, then super profit making companies are also to be excluded from the comparables for determining the ALP. Being so, in our opinion, the Assessing Officer has to recalculate the ALP after excluding only the data of the companies which have losses due to extraordinary reasons. In other words, if there is loss in ordinary course of business which is normal/nominal cannot be excluded from the comparables. However, we make it clear that if there is any abnormal loss or if there is continuous loss year by year, in such situation that company data cannot ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... he requirement of such adjustment in its TP Study. During the course of TP scrutiny, the Appellant furnished a detailed computation towards the said adjustment (Pg. 998 to 1002 of the Paperbook-Part B). However, the. TPO erroneously rejected the Appellant's claim for the said adjustment. It is a settled law that an adjustment for the differences in the levels of working capital ought to be made, to for a proper comparability analysis. It is essential to adjust for differences in the levels of working capital between the Appellant and comparable companies, as the variance in the said levels directly impacts margins. 46. The claim for the said adjustment is also supported by Rule 1oB(1)(e)(iii) of IT Rules provides that the net profit margin arising in comparable uncontrolled transactions should be adjusted to take into account the differences, if any, between the international transaction and the comparable uncontrolled transactions which could materially affect the amount of net profit margin in the open market. Further support can also be drawn from Rule 1oB(3)(ii) of the IT Rules, which provides that reasonably accurate adjustments can be made to eliminate the material eff ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... computation could be made based on reliable data, in view of sub-rule 10B of Income Tax Rules. Hence the plea of the assessee is to be rejected. 49. We have heard both the parties and perused the material on record. This issue came for consideration before the Tribunal in the case of M/s. Inflow Technologies P. Ltd. in ITA Nos.3338 3339/Bang/2018, order dated 4.8.2021 wherein it was observed as under:- 7.4 We have heard rival submissions and perused the material on record. The solitary reason assigned by the TPO which was endorsed by the DRP is that the assessee had not demonstrated the impact of working capital adjustment on profit margin of assessee as well as the comparable companies. In this context, we find on identical facts, the Bangalore Bench of the Tribunal in the case of Yahoo Software Development India Pvt. Ltd. v. JCIT (supra) had held that when the details required for working capital adjustment has been provided by the assessee, the Revenue Authorities were not justified in denying the claim of the assessee for deduction. The relevant finding of the Bangalore Bench of the Tribunal, reads as follow:- 14. We have heard the rival submissions. The relev ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... or to be employed and the risks assumed, by the respective parties to the transactions; (c) the contractual terms (whether or not such terms are formal or in writing) of the transactions which lay down explicitly or implicitly how the responsibilities, risks and benefits are to be divided between the respective parties to the transactions; (d) conditions prevailing in the markets in which the respective parties to the transactions operate, including the geographical location and size of the markets, the laws and Government orders in force, costs of labour and capital in the markets, overall economic development and level of competition and whether the markets are wholesale or retail. (3) An uncontrolled transaction shall be comparable to an international transaction [or a specified domestic transaction] if- (i) none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged or paid in, or the profit arising from, such transactions in the open market; or (ii) reasonably accurate adjustments can be made to eliminate the material ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... and compensate for the timing effect. 14. The opposite applies to higher levels of accounts payable. By carrying high accounts payable, a company is benefitting from a relatively long period to pay its suppliers. It would need to borrow less money to fund its purchases and/or benefit from an increase in the amount of cash surplus available to invest. In a competitive environment, the cost of goods sold should include an element to reflect these payment terms and compensate for the timing effect. 15. A company with high levels of inventory would similarly need to either borrow to fund the purchase, or reduce the amount of cash surplus which it is able to invest. Note that the interest rate July 2010 Page 6 might be affected by the funding structure (e.g. where the purchase of inventory is partly funded by equity) or by the risk associated with holding specific types of inventory) 16. Making a working capital adjustment is an attempt to adjust for the differences in time value of money between the tested party and potential comparables, with an assumption that the difference should be reflected in profits. The underlying reasoning is that: A company will n ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ot lead to reliable results. 20. The TPO also placed reliance on a decision of Chennai ITAT in the case of Mobis India ITA No.2112/Mds/2011 (2013) 38 taxmann.com. That decision was based on the factual aspect that the Assessee was not able to demonstrate how working capital adjustment was arrived at by the Assessee. Therefore, nothing turns on the decision relied upon by the CIT(A) in the impugned order. In the matter of determination of Arm s Length Price, it cannot be said that the burden is on the Assessee or the Department to show what is the Arm s Length Price. The data available with the Assessee and the Department would be the starting point and depending on the facts and circumstances of a case further details can be called for. As far as the Assessee is concerned, the facts and figures with regard to his business has to be furnished. Regarding comparable companies, one has to fall back upon only on the information available in the public domain. If that information is insufficient, it is beyond the power of the Assessee to produce the correct information about the comparable companies. The Revenue has on the other hand powers to compel production of the required deta ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... account the differences, if any, between the international transaction and the comparable uncontrolled transactions which could materially affect the amount of net profit margin in the open market. It is not the case of the TPO/DRP that differences in working capital requirements of the international transaction and the uncontrolled comparable transactions is not a difference which will materially affect the amount of net profit margin in the open market. If for reasons given by the revenue authorities working capital adjustment cannot be allowed to the profit margins, then the comparable uncontrolled transactions chosen for the purpose of comparison will have to be treated as not comparable in terms of Rule 10B(3) of the Rules, which provides as follows:- (3) An uncontrolled transaction shall be comparable to an international transaction if- i) none of the differences, if any, between the transactions being compared, or between the enterprises entering into such transactions are likely to materially affect the price or cost charged to paid in, or the profit arising from, such transactions in the open market; or (ii) reasonably accurate adjustments can be made t ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ed for working capital adjustment. Therefore, the Revenue Authorities were not justified in denying the claim of the assessee for deduction. Hence, the AO / TPO is directed to allow the working capital adjustment in the light of the material placed on record, after affording a reasonable opportunity of hearing to the assessee. It is ordered accordingly. 50. In view of the above order of the Tribunal, we remit this issue to the AO/TPO with similar directions. 51. Ground Nos. 3 to 8 are as follows:- Disallowance of depreciation claimed by the Assessee on Intangible assets on account of slump purchase 3. That on the facts and circumstances of the case, the Learned AO / DRP erred in disallowing depreciation on various intangibles including but not limited Goodwill arising on account of slump purchase amounting to INR 15,22,85,504 claimed by the Assessee during the year. The Learned AO has ignored that intangibles comprise of various assets. 4. The Learned AO / DRP erred in invoking the sixth (originally fifth proviso) to section 32(1)(ii) of the Act and disallowing the claim of depreciation under section 36 of the Act (a) despite having admitted in page no. 7 of th ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... pellant, in its books of account, over a period of 5 years, in line with the accounting standards and general practices. The goodwill amortisation in the books of the Appellant for the Impugned AY amounted to INR 15.23 Crores. Subsequently, in determining the taxable income for the Impugned Year, the Appellant claimed depreciation on goodwill at the rate of 25% u/s. 32(1)(ii) of the Act, in its Return of Income furnished for the Impugned AY. 54. The AO rejected the valuation report and the value of goodwill recorded by the Appellant, by erroneously alleging that the said valuation was undertaken using the DCF method which is not an acceptable method in the present case. He failed to appreciate that DCF is only one of the methods adopted, and the final valuation is the weighted average of the two methods as stated above. 55. In light of the above, the AO concluded that the genuineness and the claim of Purchase Consideration is questionable as it is fixed at an abnormally high value, in comparison to the net asset value of the business. On this basis, the Ld. AO rejected the Purchase Consideration paid, and fixed the same at the book value of Net Assets acquired, in order to el ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... llant furnished all the details and documents called for by the Ld. AO during the course of the assessment. Again, the TPO merely made a generic allegation that the details were not furnished, without recording a finding as to which details were not called for but not furnished. 61. In light of the above, the Appellant submits that the AO cannot simply disregard the valuation reports obtained from an expert independent valuer, without establishing that the said valuation is materially flawed based on the opinion of an export. Further, the examination of the AO ought to be confined to identification of any errors in the valuation, that is undertaken based on the method employed by the valuer. The AO cannot reject the valuation methodology in itself. 62. Further, DCF is an internationally recognized, which is also recognized and accepted by the RBI, ICAI as well as under the provision of the Act. Hence, the rejection of such an established method by the AO merely because it involves assumptions, is without any basis. A valuation exercise in itself, irrespective of the method adopted, is not an exact science and can never be done with arithmetic precision and involves several as ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... that were used by another person at any time for the purpose of their business, prior to their acquisition'. In the present case, the AO is essentially rejecting the 'actual cost' of G/W recorded pursuant to slump sale, and the said goodwill at the time of acquiring the business by paying a premium and is not an asset that was previously used for business and thereafter transferred. 66. In light of the above, the ld. AR submitted that in the absence of invocation of the above mentioned provision, the AO is not empowered under the Act, to determine the 'actual cost' of an asset, which is defined under section 43(1) of the Act to mean the actual cost of the assets to the Assessee, reduced by that portion of the cost thereof, if any, as has been met directly or indirectly by any other person or authority. In the present case, the 'actual cost' for acquiring the business is the Purchase Consideration paid by the Appellant, and the same cannot be rejected and determined by the AO. Reliance was placed on the decision of Ashwin Vanaspati Industries, 255 ITR 26 (Guj). 67. Further, it was submitted that the lower authorities questioned the genuineness of tr ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... Toyo Engineering India Limited, TS-811-HC-2012 Volvo India Pvt. Ltd., TS-391-ITAT-2019 Dorma India Pvt Ltd., TS-735-ITAT-2019 Erroneous invocation of the sixth proviso to section 32(1) of the Act 69. The ld. AR submitted that invoking the sixth proviso to Section 32(1) of the Act by the. AO in the present case is totally misplaced and not justified. The said proviso does not restrict the claim of depreciation on goodwill arising pursuant to a slump sale. It is intended only for apportioning the amount of depreciation between the predecessor company and the successor company, based on the respective periods of the use of an asset during the previous year. 70. The sixth proviso is therefore applicable, only in case of assets already existing in the books of predecessor company on which predecessor company was claiming depreciation before slump purchase, and it is not applicable on assets recognized only by successor company pursuant to such slump purchase. The legislative intent behind the introduction of the said proviso was to curb the practice of claiming' depreciation on the 'same ass ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... value of goodwill in the books of account was said to be on account of revaluation of assets. In view of this, the depreciation thereon was restricted to actual cost of asset, having regard to Explanation 3 of section 43(1). 75. Additionally, 6th proviso to section 32(1) of the Act was invoked. It was observed that the transferor KBDL had not claimed any depreciation on G/W prior to the transfer and hence, applying said proviso, it was concluded that no depreciation shall be allowed in the hands of UB, since the transferor did not claim any depreciation thereon. It was therefore concluded that the amalgamated company cannot claim such depreciation that was never claimed by the amalgamating company. 76. The above basis formed the twin grounds on which the depreciation was denied to the UB. However, it is important to note that the Tribunal has clarified at para 15 of the decision that goodwill is a depreciable asset having regard to the Supreme Court judgment in Sniffs Securities (Supra). Amendment by Finance Act 2021 clarifies the position on Goodwill depreciation 77. The Finance Act, 2021, inserted a series of amendments in relation to the allowance of depreciati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... port in question cannot be relied upon and as such is liable for rejection. 82. We have heard both the parties and perused the material on record. Similar issue came for consideration before the Delhi Tribunal in the case of Rockland Diagnostics Services P. Ltd. in ITA No.316/Del/2019. The Tribunal vide order dated 25.2.2021 remitted the issue to the AO with the following observations:- 5.0 We have heard the rival submissions and have also perused the material on record. So far as the issue of addition of Rs.1,07,82,453/- is concerned, it is seen that the Assessing Officer has disregarded the valuation report mainly on the ground that valuation of equity shares was based on projection of revenue which did not match with the actual revenue during the subsequent years. In addition, the Assessing Officer has also adopted the Fair Market Value of the shares at Rs.10/- being the price paid by the Rockland Hospital Limited to acquire shares of erstwhile shareholders in the month of November, 2014. Apparently, the Assessing Officer has proceeded on mere assumptions and surmises while disregarding the valuation report submitted by the assessee. The assessee has applied the DCF meth ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... tial value of business at that particular time and also keeping in mind underline factors that may change over the period of time and thus, the value which is relevant today may not be relevant after certain period of time. ... 33. In any case, if law provides the assessee to get the valuation done from a prescribed expert as per the prescribed method, then the same cannot be rejected because neither the Assessing Officer nor the assessee have been recognized as expert under the law. 5.1 Similarly, it has been held that where a valuation report is to be rejected, the authority should pinpoint any specific inaccuracies or short comings in the DCF valuation report. In the case of Intelligrape Software Pvt. Ltd., vs. ITO in ITA No.3925- Del2018 (Delhi Trib.), it has been held as under: 23. The AO was not able to pinpoint any specific inaccuracies or short comings in the DCF valuation report of the Chartered Accountant/Valuer other than stating that year-wise results as projected are not matching with the actual results declared in the final accounts. Before the Id. CIT (A), reasons for variation between projected and actuals were duly explained. The Ld. CIT (A) ha ..... 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