In the result, the appeal of the assessee is dismissed
Bench: Ms. Astha Chandra & Shree G.D. Padmahshali
Transfer Pricing Officer for determination of arm's length price in respect of international transactions reported for the relevant assessment year. Then paragraph 4, along with its sub paragraphs 4.1 to 47 deal with disallowance under section 40(a)(ia) in the context of commission exceeding Re. 18.00 crore paid by the Assessee during the relevant assessment year, even though