TP Adjustment - TPO rejected the TP study undertaken by the ...

CIT(A)'s Order Criticized for Lack of Clarity in Deleting TPO's Transfer Pricing Adjustments; Insufficient Justification Noted.

June 28, 2022

Case Laws Income Tax AT

TP Adjustment - TPO rejected the TP study undertaken by the assessee and proceeded to apply TNMM at the entity level which the assessee company has objected to - CIT(A) deleted the additions - We have perused the order passed by the CIT(A) particularly para 9 which is cryptic in nature and fails to lead to the specific conclusions as to why the TP adjustment made by the TPO are being deleted. Merely on the basis of generic observations without going into the functionality of the particular segments/international transactions TP adjustment cannot be deleted. - AT

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TP Adjustment - TPO rejected the TP study undertaken by the ...

CIT(A)'s Order Criticized for Lack of Clarity in Deleting TPO's Transfer Pricing Adjustments; Insufficient Justification Noted.

June 28, 2022

Case Laws Income Tax AT

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