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HC held that the Transfer Pricing Officer's (TPO) determination is binding on the Assessing Officer (AO) and the AO cannot independently determine the arm's-length price (ALP) without complying with s.92CA(1). Where the TPO issued an order without making adjustments, the AO had no jurisdiction to reopen or revise assessment on identical material already considered by the TPO absent fresh tangible material. Consequently, the petition by the taxpayer succeeds: the AO's action was quashed, the ALP must stand as determined through the TPO process, and any assessment based on unilateral AO determination without reference to the TPO is set aside.
HC held that the Transfer Pricing Officer's (TPO) determination is binding on the Assessing Officer (AO) and the AO cannot independently determine the arm's-length price (ALP) without complying with s.92CA(1). Where the TPO issued an order without making adjustments, the AO had no jurisdiction to reopen or revise assessment on identical material already considered by the TPO absent fresh tangible material. Consequently, the petition by the taxpayer succeeds: the AO's action was quashed, the ALP must stand as determined through the TPO process, and any assessment based on unilateral AO determination without reference to the TPO is set aside.
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