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In the result, assessee’s appeal is partly allowed
Bench: Shri Saktijit Dey & Shri Rajesh Kumar
section 92C of the Act r/w rule 10B. As discussed elsewhere in this order, such determination of arm's length price on ad–hoc / estimation basis is not permissible under the scheme of the Act as the Transfer Pricing Officer is duty bound to determine the arm's length price by following any one of the most appropriate method prescribed