https://www.taxtmi.com/caselaws?id=390270 The Tribunal held that Transfer Pricing provisions apply to an assessee eligible for tax exemption under Section 10A, emphasizing the need to prevent profit shifting. It rejected the requirement to demonstrate tax avoidance, interpreting statutory provisions plainly. International tax treaties do not override domestic laws on Transfer Pricing. Procedural rules for TPO reference do not mandate prior hearing. The Tribunal ruled against the assessee, affirming the applicability of Section 92 without requiring a tax avoidance motive, and dismissing objections based on non-discrimination clauses and procedural grounds. en-us Thu, 24 Oct 2019 00:00:00 +0530 Fri, 27 Dec 2019 08:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=390270 The Tribunal held that Transfer Pricing provisions apply to an assessee eligible for tax exemption under Section 10A, emphasizing the need to prevent profit shifting. It rejected the requirement to demonstrate tax avoidance, interpreting statutory provisions plainly. International tax treaties do not override domestic laws on Transfer Pricing. Procedural rules for TPO reference do not mandate prior hearing. The Tribunal ruled against the assessee, affirming the applicability of Section 92 without requiring a tax avoidance motive, and dismissing objections based on non-discrimination clauses and procedural grounds. Case-Laws Income Tax Thu, 24 Oct 2019 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=390270