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Income Tax - Highlights / Catch Notes

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TP Adjustment - the TPO is erred in adopting CUP method for few ...

Income Tax

December 14, 2022

TP Adjustment - the TPO is erred in adopting CUP method for few transactions when he has accepted overwhelming majority of transactions under TNMM method. The DRP without appreciating the above facts, simply sustained TP adjustment suggested by the TPO. Hence, we direct the AO/TPO to delete TP adjustment made towards few transactions by adopting CUP as most appropriate method. - AT

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