Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Company oppression/mismanagement petition amendments and maintainability after alleged share transfer and forgery claims; tribunal order quashed for l...
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
Assessing Officer's reference to the Dispute Resolution Panel under section 144C was invalid where the Transfer Pricing Officer made no variation following a section 92CA request. The tribunal accepted the assessee's contention that an 'eligible assessee' status under section 144C is absent absent any proposed TPO variation, and therefore the AO wrongly invoked the DRP reference. Consequence: the assessment order was quashed and the assessee's appeal allowed.
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