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2011 (11) TMI 73 - HC - Income TaxWhether, on the facts and circumstance of the case, the Income Tax Appellate Tribunal erred in deciding that the Transfer Pricing Officer (TPO) could not take cognizance suo moto of any international transaction for adjustment in the Arms Length Price (ALP) under Section 92CA of the Income-tax Act, 1961 - held that:- It is quite possible that in the case of a particular assessee, there may be several international transactions and the Assessing Officer may only wish to refer some of those international transactions for the purposes of computing the arm’s length price while in respect of others, he may compute the arm’s length price himself. Thus, the jurisdiction of the Transfer Pricing Officer is limited and restricted to computing the arm’s length price of only those international transactions which have been specifically referred to him by the Assessing Officer. - ITAT committed no error in deciding that the Transfer Pricing Officer could not take cognizance suo moto of any international transaction for adjustment in the arm’s length price under Section 92C of the Income-tax Act, 1961. - Decided against the revenue.
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