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ITAT upholds the assessment under s.143(3) read with s.144C(13), finding the reference under s.92CA(1) valid and the TPO acted within jurisdiction; the assessment order is not void and Grounds 1-3 are dismissed. The Project Office is characterized as merely an executing arm of the Head Office; transfer pricing adjustments for onshore services are sustained as the taxpayer failed to demonstrate arm's-length remuneration. For offshore supplies, the Tribunal concludes the Project Office's post-supply obligations created a taxable nexus in India, justifying attribution under s.9 and Article 7 of the India-China DTAA. The CUP method is rejected as the MAM due to lack of strict comparability; the impugned TP adjustments are consequently upheld.
ITAT upholds the assessment under s.143(3) read with s.144C(13), finding the reference under s.92CA(1) valid and the TPO acted within jurisdiction; the assessment order is not void and Grounds 1-3 are dismissed. The Project Office is characterized as merely an executing arm of the Head Office; transfer pricing adjustments for onshore services are sustained as the taxpayer failed to demonstrate arm's-length remuneration. For offshore supplies, the Tribunal concludes the Project Office's post-supply obligations created a taxable nexus in India, justifying attribution under s.9 and Article 7 of the India-China DTAA. The CUP method is rejected as the MAM due to lack of strict comparability; the impugned TP adjustments are consequently upheld.
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