2016 (11) TMI 1567 - SC - Income Tax

TPA- MAM - CUP accepted by Transfer Pricing Officer in subsequent assessment years by accepting quotation for benchmarking international transaction - Held that - in the subsequent years the comparable uncontrolled price method has been accepted by the Transfer Pricing Officer. Learned senior counsel though sought for some time to file an affidavit as to whether the acceptance was after accepting quotations we do not find any need for the same before this Court since for the subsequent years from 2007-08 onwards the same has been accepted. If there is some irregularity on the part of any of the officers it is for the Revenue to take appropriate action. The special leave petition is dismissed.

Summary

The Supreme Court of India dismissed the special leave petition. The comparable uncontrolled price method (CUP) was accepted by the Transfer Pricing Officer in subsequent assessment years. The question of law is kept open.