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No concealment penalty if TP additions were made due to change of method of determining ALP

November 7, 2019[2019] 111 77 (Delhi - Trib.)

TRANSFER PRICING: Where TPO made TP adjustment qua international transactions by using a particular method i.e., TNM method, any further addition by changing MAM from TNM method to CUP method was not sufficient to attract provisions contained under section 271(1)(c) as it is a mere change of opinion
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