In the result, the transfer pricing adjustment so made by the AO and confirmed by the ld CIT(A) amounting to Rs 89,22,420/- is hereby set-aside and the ground of appeal is allowed
Bench: Or At The Time Of Hearing.”
pricing principles. Hence Ld. TPO, Ld. A.O & Worthy CIT(A) are not justified to hold that once these items are reported in Form 3CEB as specified Domestic Transactions being any expenditure in respect of which payment has been made or is to be made to any person referred to in section 40A(2)(b) of the Income