Transfer pricing adjustment sustained where factual findings and reverified computation were not effectively challenged.

Transfer pricing adjustment and allied additions were found not to warrant interference because the assessee did not effectively contest the assessment and TP findings, the DRP directions were substantially complied with, and the computation was reverified with a reduction in the adjustment. The leave encashment addition was also examined on the record, and the material available did not dislodge the factual findings. As a result, the impugned additions were sustained and the appeal failed.

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Issues: Whether the transfer pricing adjustment and allied additions required interference.

Analysis: The assessee did not effectively contest the findings recorded in the assessment and transfer pricing proceedings. The revenue authorities pointed out that the directions of the Dispute Resolution Panel were substantially complied with, the computation was reverified, and the transfer pricing adjustment was reduced. The addition relating to leave encashment was also examined on the record. On the material available, the findings of fact were not dislodged.

Conclusion: No interference was warranted with the transfer pricing determination or the related addition, and the assessee's appeal failed.

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