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TPO couldn’t determine ALP on estimation basis merely because assessee didn’t furnish certain doc. as evidence

September 12, 2018[2018] 96 649 (Mumbai)

IT/ILT: There is no provision under Act empowering TPO to determine arm's length price on estimate basis, that too, by entertaining doubts with regard to business expediency of payment and in process stepping into shoes of Assessing Officer for making disallowance under section 37(1)

IT/ILT: Non-furnishing of certain documentary evidences does not empower TPO to embark upon determining arm's length price of international transaction on estimate basis
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