The Mumbai bench of the Income Tax Appellate Tribunal (ITAT) upheld the determination of Arm’s Length Price (ALP) on reimbursement of third-party costs incurred under Comparable Uncontrolled Price (CUP) and directed the deletion of the proposed adjustment. M/s. Transocean Drilling Services (I) Pvt. Ltd, the assessee company filed the returns electronically on 30/11/2012 declaring a…
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