Directive upheld: TPO must consider assessee's transfer pricing studies and apply CUP method for intra-group services SC dismissed the special leave petition, upholding the HC's direction that the TPO must examine the assessee's transfer-pricing studies concerning ...
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Directive upheld: TPO must consider assessee's transfer pricing studies and apply CUP method for intra-group services
SC dismissed the special leave petition, upholding the HC's direction that the TPO must examine the assessee's transfer-pricing studies concerning intra-group services and the application of the CUP method. The HC had noted that the TPO appeared not to have considered the assessee's valuation analysis, while CIT(A) and the ITAT had concurrently found receipt of intra-group services. The SC found no ground to interfere with the HC order and accordingly dismissed the petition.
Supreme Court reviewed the record and the arguments and concluded there was "no good ground to interfere with the impugned order passed by the High Court." Consequently, the "Special Leave Petition is, accordingly, dismissed." The decision leaves the High Court's order intact and disposes of any pending applications. The Court's action is summary in nature, resting on review of materials on record and the absence of viable grounds to disturb the lower court's determination.
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