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ITAT set-aside TP additions as allocation of exp. was based upon global agreement supported by CPA certificate

December 14, 2018[2018] 100 taxmann.com 165 (Mumbai - Trib.)

IT/ILT: Where TPO rejected ALP of cost allocated to assessee and made additions by stating that assessee failed to produce supporting documents/evidence to substantiate that services were rendered by AE, however, it was found that assessee's allocation of expenses was based upon a global agreement between AEs and was supported by CPA certificate, additions so made were to be set aside

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