https://www.taxtmi.com/caselaws?id=211075 The Tribunal reinstated the Assessing Officer's adjustments based on the Transfer Pricing Officer's determination of the Arm's Length Price, holding that the transfer pricing provisions were applicable to the international transactions between the assessee and its non-resident Associate Enterprises, despite the transactions occurring within India. The Tribunal emphasized that the nature of the transaction being international triggered the transfer pricing provisions, irrespective of any motive to shift profits or evade taxes. The department's appeal was allowed, and the Tribunal's decision clarified the mandatory application of transfer pricing provisions for international transactions as defined under section 92B(1) of the Income Tax Act. en-us Fri, 27 May 2011 00:00:00 +0530 Sat, 03 Mar 2012 11:13:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=211075 The Tribunal reinstated the Assessing Officer's adjustments based on the Transfer Pricing Officer's determination of the Arm's Length Price, holding that the transfer pricing provisions were applicable to the international transactions between the assessee and its non-resident Associate Enterprises, despite the transactions occurring within India. The Tribunal emphasized that the nature of the transaction being international triggered the transfer pricing provisions, irrespective of any motive to shift profits or evade taxes. The department's appeal was allowed, and the Tribunal's decision clarified the mandatory application of transfer pricing provisions for international transactions as defined under section 92B(1) of the Income Tax Act. Case-Laws Income Tax Fri, 27 May 2011 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=211075