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The appeal of the assessee is allowed
Bench: Shri N. K. Billaiya & Ms Suchitra Kamble
143(3) read with section 144C of the Income-tax Act (“the Act”) at an income of Rs. 184,341,870 as against INR 72,692,430 returned income. 3. Transfer Pricing Issues: 3.1 That on the facts and circumstances of the case and in law, the AO / DRP /transfer pricing officer (“TPO”) have erred in disallowing payment