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ITAT upheld that the TPO's substitution of projected figures...
Tax authority's substitution of projected figures with actuals overturned; original acquisition valuation upheld; transfer pricing issues remitted for ALP determination
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ITAT upheld that the TPO's substitution of projected figures with actuals in valuation of specified assets was unwarranted; the original acquisition valuation, supported by board resolution and independent valuer, must stand and the TPO cannot rework projections against actual performance. TP adjustments regarding support services, R&D services comparables, and selection of the most appropriate method were remitted to AO/TPO for de novo determination of ALP, benchmarking and FAR-based comparable selection; AO/TPO to apply MAM/TNMM/RPM as appropriate, give the assessee opportunity of hearing, and consider submission of AE cost data, allocation keys and working capital adjustments. The remitted grounds are allowed for statistical purposes.
ITAT upheld that the TPO's substitution of projected figures with actuals in valuation of specified assets was unwarranted; the original acquisition valuation, supported by board resolution and independent valuer, must stand and the TPO cannot rework projections against actual performance. TP adjustments regarding support services, R&D services comparables, and selection of the most appropriate method were remitted to AO/TPO for de novo determination of ALP, benchmarking and FAR-based comparable selection; AO/TPO to apply MAM/TNMM/RPM as appropriate, give the assessee opportunity of hearing, and consider submission of AE cost data, allocation keys and working capital adjustments. The remitted grounds are allowed for statistical purposes.
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