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While computing ALP of international transaction under RPM/CPM abnormal exp. to be considered

August 23, 2018[2018] 96 taxmann.com 425 (Mumbai - Trib.)

IT/ILT: While computing ALP of international transactions under RPM or CPM, TPO should grant adjustment on account of abnormal expenses

IT/ILT: Where assessee had about four years of experience in relevant field and, moreover, it could not provide any material to show that it was continue to face difficulties peculiar to start up phase, tax authorities were justified in rejecting claim for start up phase adjustment to assessee

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