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The Court admitted 2 questions of law raised by Revenue on comparables selection and risk adjustment viz. Further, the Tribunal refused to remit the matter to the AO by relying on the Gujarat HC ruling in Rajesh Babubhai Damania as it would amount to giving second innings to the AO when sufficient material was available before him on record which was impermissible.
The Tribunal observed that there was no evidence to demonstrate the co-relation between the growth and quantum of AMP-expenditure, and hence the addition on basis of mere surmises could not be sustained.
Comments 1. Search the product to add. Learn more about the benefits of unionization and how to organize a union at your workplace.