Bench: CHIEF JUSTICE,C M JOSHI
disallowance was founded on the proviso to Section 92C(4) of the Act. - 12 - HC-KAR NC: 2025:KHC:36360-DB ITA No. 107 of 2025 C/W ITA No. 106 of 2025 17. It is material to note that the TP adjustments are made pursuant to the APA entered into by the Assessee with CBDT. Section 92CC