https://www.taxtmi.com/caselaws?id=400068 The tribunal condoned a 32-day delay in filing the appeal due to reasonable circumstances. It addressed a transfer pricing adjustment concerning fixed assets purchased from an AE, where the TPO had treated the transaction value as Nil. The tribunal found the TPO's determination of the Arm's Length Price (ALP) unsustainable, as it did not apply any prescribed method and failed to justify the adjustment. Citing the Bombay HC's decision, the tribunal emphasized that the TPO's role is limited to determining ALP, not questioning expenditure genuineness. Consequently, the tribunal allowed the appeal, deleting the TPO's addition, despite the order's delayed pronouncement due to COVID-19. en-us Mon, 27 Jul 2020 00:00:00 +0530 Tue, 05 Nov 2024 11:54:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=400068 The tribunal condoned a 32-day delay in filing the appeal due to reasonable circumstances. It addressed a transfer pricing adjustment concerning fixed assets purchased from an AE, where the TPO had treated the transaction value as Nil. The tribunal found the TPO's determination of the Arm's Length Price (ALP) unsustainable, as it did not apply any prescribed method and failed to justify the adjustment. Citing the Bombay HC's decision, the tribunal emphasized that the TPO's role is limited to determining ALP, not questioning expenditure genuineness. Consequently, the tribunal allowed the appeal, deleting the TPO's addition, despite the order's delayed pronouncement due to COVID-19. Case-Laws Income Tax Mon, 27 Jul 2020 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=400068