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In the result, appeal stands partly allowed
Bench: Shri Saktijit Dey & Shri Ashwani Taneja
36. We have heard the rival contentions carefully in the light of the facts and material on record as well as the decisions relied upon by both the parties. At this stage, we must observe, in the earlier part of the order, we have disapproved the approach of the Transfer Pricing Officer in rejecting the transfer pricing analysis