https://www.taxtmi.com/caselaws?id=286728 The case involved challenges to the validity of the reference by the Assessing Officer (AO) to the Transfer Pricing Officer (TPO) for determining the Arm's Length Price (ALP), rejection of the Comparable Uncontrolled Price (CUP) method, selection of comparables, compliance with DRP directions, underutilization adjustment, preference for internal comparables, adjustment for unutilized capacity, and consideration of submissions by the assessee-company. Ultimately, the matter was remitted back to the AO/TPO for a fresh analysis of the Transfer Pricing study, indicating a partial allowance of the appeal for further review and consideration of relevant factors in determining the ALP. en-us Tue, 04 Apr 2017 00:00:00 +0530 Fri, 13 Mar 2020 10:14:57 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=286728 The case involved challenges to the validity of the reference by the Assessing Officer (AO) to the Transfer Pricing Officer (TPO) for determining the Arm's Length Price (ALP), rejection of the Comparable Uncontrolled Price (CUP) method, selection of comparables, compliance with DRP directions, underutilization adjustment, preference for internal comparables, adjustment for unutilized capacity, and consideration of submissions by the assessee-company. Ultimately, the matter was remitted back to the AO/TPO for a fresh analysis of the Transfer Pricing study, indicating a partial allowance of the appeal for further review and consideration of relevant factors in determining the ALP. Case-Laws Income Tax Tue, 04 Apr 2017 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=286728