https://www.taxtmi.com/caselaws?id=250887 Where the existence and extent of alleged offshore operations are not established by reliable evidence, attribution of income and the related transfer pricing adjustment cannot be sustained on the existing record. The ITAT noted a serious dispute over whether the contract was divisible into onshore and offshore components, whether the outside-India activities were separately identifiable, and whether the claimed receipts and corresponding expenditure were properly supported. It therefore held that the proper attribution of income required fresh factual verification by the Assessing Officer and Transfer Pricing Officer after giving the assessee an opportunity to be heard, and restored the substantive additions for de novo examination. en-us Thu, 31 Jul 2014 00:00:00 +0530 Thu, 28 Aug 2014 08:42:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=250887 Where the existence and extent of alleged offshore operations are not established by reliable evidence, attribution of income and the related transfer pricing adjustment cannot be sustained on the existing record. The ITAT noted a serious dispute over whether the contract was divisible into onshore and offshore components, whether the outside-India activities were separately identifiable, and whether the claimed receipts and corresponding expenditure were properly supported. It therefore held that the proper attribution of income required fresh factual verification by the Assessing Officer and Transfer Pricing Officer after giving the assessee an opportunity to be heard, and restored the substantive additions for de novo examination. Case-Laws Income Tax Thu, 31 Jul 2014 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=250887