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Substantive Adjustment
4. Without prejudice to Ground no 2 and 3. On the facts and circumstances of the case and in law, the Ld. DRP/AO/TPO grossly erred in enhancing the income of the Appellant by INR 12,01,20,375 on a substantive basis by applying Residual Profit Split Method ("RPSM") which is mere extension of BLT for the purpose of benchmarking the AMP expense incurred by the Appellant. In doing so, the Ld. AO/Ld. TPO grossly erred in:
4.1. the application of RPSM by following erroneous, incorrect methodology based on fallacious assumptions and not in accordance with the provision of section 92C of the Act read with Rule 108(1)(d) of the Income-tax Rules, 1962: