https://www.taxtmi.com/caselaws?id=241115 The Appellate Tribunal upheld the addition to the arm's length price (ALP) of certain international transactions for the assessment year 2006-07, dismissing the assessee's appeal. The dispute centered on transfer pricing adjustments totaling Rs.2,87,72,311, with the ALP set at Rs.4,14,53,877 compared to the declared value of Rs.1,58,12,470. The Tribunal rejected the use of a quotation without evidence of actual transactions or comparable cases to substantiate the ALP under the Comparable Uncontrolled Price (CUP) method. Emphasizing the burden of proof on the assessee, the judgment underscored the necessity of providing concrete evidence from comparable cases to support pricing adjustments under transfer pricing regulations. en-us Fri, 13 Dec 2013 00:00:00 +0530 Tue, 06 Feb 2018 16:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=241115 The Appellate Tribunal upheld the addition to the arm's length price (ALP) of certain international transactions for the assessment year 2006-07, dismissing the assessee's appeal. The dispute centered on transfer pricing adjustments totaling Rs.2,87,72,311, with the ALP set at Rs.4,14,53,877 compared to the declared value of Rs.1,58,12,470. The Tribunal rejected the use of a quotation without evidence of actual transactions or comparable cases to substantiate the ALP under the Comparable Uncontrolled Price (CUP) method. Emphasizing the burden of proof on the assessee, the judgment underscored the necessity of providing concrete evidence from comparable cases to support pricing adjustments under transfer pricing regulations. Case-Laws Income Tax Fri, 13 Dec 2013 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=241115