https://www.taxtmi.com/caselaws?id=375095 The court held that the amendments to Section 92C(2) of the Income Tax Act, 1961 were not clarificatory and did not allow for the acceptance of the invoiced price based on a 5% variation. The court clarified that the CBDT Circular could not mitigate statutory provisions and that the option to select one of the prices determined by the Transfer Pricing Officer applied only when more than one price was determined. The court affirmed the Appellate Tribunal's order, ruling in favor of the Revenue and rejecting the appeal. en-us Fri, 18 Jan 2019 00:00:00 +0530 Thu, 12 Mar 2020 17:04:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=375095 The court held that the amendments to Section 92C(2) of the Income Tax Act, 1961 were not clarificatory and did not allow for the acceptance of the invoiced price based on a 5% variation. The court clarified that the CBDT Circular could not mitigate statutory provisions and that the option to select one of the prices determined by the Transfer Pricing Officer applied only when more than one price was determined. The court affirmed the Appellate Tribunal's order, ruling in favor of the Revenue and rejecting the appeal. Case-Laws Income Tax Fri, 18 Jan 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=375095