Electronic WhatsApp evidence without authentication or independent corroboration cannot sustain an unexplained-investment addition based on third-part...
Mutual current-account transactions excluded from deemed dividend treatment where no fresh borrowing arose; unsupported unsecured-loan addition also f...
ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely referenced Comparable Uncontrolled Price (CUP) method without identifying actual uncontrolled transaction prices or conducting appropriate comparability analysis. Consistent with precedent, the tribunal found the ALP adjustment procedurally invalid, as no specific transfer pricing method was systematically applied. Consequently, the tribunal deleted the transfer pricing addition, holding that the assessment was not in accordance with legal requirements for determining arm's length pricing.
ITAT ruled that the Transfer Pricing Officer (TPO) improperly determined Arm's Length Price (ALP) without following prescribed methods under Rule 10B. The TPO merely referenced Comparable Uncontrolled Price (CUP) method without identifying actual uncontrolled transaction prices or conducting appropriate comparability analysis. Consistent with precedent, the tribunal found the ALP adjustment procedurally invalid, as no specific transfer pricing method was systematically applied. Consequently, the tribunal deleted the transfer pricing addition, holding that the assessment was not in accordance with legal requirements for determining arm's length pricing.
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