https://www.taxtmi.com/caselaws?id=388941 An Additional Commissioner could validly function as a Transfer Pricing Officer under the statutory scheme, so the jurisdictional challenge failed. In benchmarking under the Transactional Net Margin Method, the assessee's international transactions had to be tested in the hands of the Indian enterprise; the foreign associated enterprise could not be taken as the tested party, and adjustments had to remain confined to international transactions, with Indian domestic sales not used as comparables unless market differences were reliably neutralised. The fixed-asset import adjustment and the disallowance of expense provisions both required fresh factual verification, so those matters were remitted to the Assessing Officer and the Transfer Pricing Officer for reconsideration. en-us Mon, 25 Nov 2019 00:00:00 +0530 Wed, 27 Nov 2019 08:19:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=388941 An Additional Commissioner could validly function as a Transfer Pricing Officer under the statutory scheme, so the jurisdictional challenge failed. In benchmarking under the Transactional Net Margin Method, the assessee's international transactions had to be tested in the hands of the Indian enterprise; the foreign associated enterprise could not be taken as the tested party, and adjustments had to remain confined to international transactions, with Indian domestic sales not used as comparables unless market differences were reliably neutralised. The fixed-asset import adjustment and the disallowance of expense provisions both required fresh factual verification, so those matters were remitted to the Assessing Officer and the Transfer Pricing Officer for reconsideration. Case-Laws Income Tax Mon, 25 Nov 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=388941