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The HC held that the impugned transfer pricing adjustment was applied to the petitioner's entire turnover/operating costs rather than being confined to international/related-party transactions, which is contrary to settled law. The petitioner may press all available submissions before the CIT(A) in the pending statutory appeal; the CIT(A) is directed to decide the appeal expeditiously, preferably within 12 months. Pending disposal of the appeal and for four weeks thereafter, the Revenue is restrained from recovering taxes and interest attributable to the excess transfer pricing adjustment (≈ Rs.11,55,90,71,049 or as correctly computed) and from taking further proceedings on that specific issue. Stay applications on other additions to be decided by the Principal Commissioner in accordance with law.
The HC held that the impugned transfer pricing adjustment was applied to the petitioner's entire turnover/operating costs rather than being confined to international/related-party transactions, which is contrary to settled law. The petitioner may press all available submissions before the CIT(A) in the pending statutory appeal; the CIT(A) is directed to decide the appeal expeditiously, preferably within 12 months. Pending disposal of the appeal and for four weeks thereafter, the Revenue is restrained from recovering taxes and interest attributable to the excess transfer pricing adjustment (≈ Rs.11,55,90,71,049 or as correctly computed) and from taking further proceedings on that specific issue. Stay applications on other additions to be decided by the Principal Commissioner in accordance with law.
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