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ALP of warranty exp. couldn't be taken as nil merely on ground that there was no need to incur said exp.

January 8, 2019[2019] 101 taxmann.com 17 (Mumbai - Trib.)
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IT/ILT-I: Where assessee reimbursed expenses incurred by its AE on providing warranty services, however, TPO determined ALP of said charges at nil on ground that there was no need to incur said expenses, since necessity of incurring expenses is beyond scope of tax authorities, impugned order passed by TPO was to be set aside

IT/ILT-II: Where TPO determined ALP of design pattern charges paid to AE at nil taking a view that assessee had not furnished any valuation certificate nor did it prove that Design Patterns were transferred at its book value by AE, since TPO had doubted assessee's claim on surmises, impugned order passed by TPO was to be set aside

IT/ILT-III: Where TPO disallowed administrative service charges paid by assessee to AE on ground that allocation of expenses was not at arm's length, in interest of natural justice, assessee was to be given one more opportunity to furnish other evidence and, thus, impugned order was to be set aside and, matter was to be remanded back for disposal afresh

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