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ITAT upheld the AO/TPO and CIT(A) findings and dismissed the appellant's challenge, affirming an upward transfer-pricing adjustment under section 92CA in respect of a specified domestic transaction between the appellant firm and its partner. The tribunal accepted the AO's conclusion that the land area and sale-deed cost asserted by the assessee were not tenable, rejected the comparable submitted as non-comparable for CUP analysis due to transaction date, and sustained recomputation of ALP at Rs.9,659 per sq. m. for 4,522 sq. m., resulting in an upward adjustment of Rs.83,20,480 to the assessee's income. Decision against the assessee.
ITAT upheld the AO/TPO and CIT(A) findings and dismissed the appellant's challenge, affirming an upward transfer-pricing adjustment under section 92CA in respect of a specified domestic transaction between the appellant firm and its partner. The tribunal accepted the AO's conclusion that the land area and sale-deed cost asserted by the assessee were not tenable, rejected the comparable submitted as non-comparable for CUP analysis due to transaction date, and sustained recomputation of ALP at Rs.9,659 per sq. m. for 4,522 sq. m., resulting in an upward adjustment of Rs.83,20,480 to the assessee's income. Decision against the assessee.
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