2023 (8) TMI 1439

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..... group services was for commercial expediency - As decided by HC [ 2022 (9) TMI 1567 - DELHI HIGH COURT] agreement between the Assessee and its AE was a composite one and could not be split up for the purposes of holding that some services are at arm s length and some are not as on viewing the agreement as a whole. It was not within the purview of the TPO to determine if some of the services result .....

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..... tioner : Mr. N Venkatraman, A.S.G., Mr. Raj Bahadur Yadav, AOR, Mr. H R Rao, Adv., Mr. Vishnu Shankar Jain, Adv., Mr. Pravartak Suhas Pathak, Adv., Mr. Udai Khanna, Adv., Mr. Purnenedu Bajpai, Adv. For the Respondent : Mr. Vishal Kalra, Adv., Mr. Ankit Saini, Adv., Mr. S.S. Tomar, Adv. ORDER Delay condoned. This Court is of the opinion that the impugned order does not call for interference. Th .....

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