ITAT remanded transfer pricing adjustments for reassessment ...

Tax Tribunal Orders Fresh Review of Transfer Pricing Methods and Trade Payables Documentation for AY 2021-22 Expense Allocation.

January 25, 2025

Case Laws Income Tax AT

ITAT remanded transfer pricing adjustments for reassessment regarding expense allocation and segmental reporting. Tribunal directed AO/TPO to verify assessee's allocation methodology consistent with AY 2021-22 practices and analyze internal CUP method for benchmarking book purchase transactions with AE. Examination to include comparison of AE discounts in controlled versus uncontrolled transactions. On trade payables enhancement issue, matter remitted to AO for verification of creditor confirmations and supporting documentation. Both grounds allowed for statistical purposes, with directive to provide assessee reasonable hearing opportunity during reassessment. AO to determine final position after examining additional evidence per legal requirements.

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ITAT remanded transfer pricing adjustments for reassessment ...

Tax Tribunal Orders Fresh Review of Transfer Pricing Methods and Trade Payables Documentation for AY 2021-22 Expense Allocation.

January 25, 2025

Case Laws Income Tax AT

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