Opportunity to furnish unsecured-loan confirmations is required before reassessment initiation; proceedings require fresh consideration after taxpayer...
Under-reporting on a first reassessment return attracts penalty, while enhanced misreporting penalty requires proof of a statutory misreporting catego...
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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TaxTMI 
TaxTMI 
of 4916 
