https://www.taxtmi.com/caselaws?id=436552 The Court upheld the Tribunal's decision to apply Advance Pricing Agreement (APA) principles for benchmarking transactions for Assessment Year (AY) 2012-13, despite APA's statutory introduction in AY 2013-14. The Court found the Tribunal's approach appropriate, emphasizing the Transfer Pricing Officer's (TPO) role in ensuring Functions, Assets, and Risks (FAR) alignment with APA principles. The decision was supported by previous judgments allowing APA adoption for years not explicitly covered. The Court concluded that no substantial question of law arose, affirming the Tribunal's application of the law and closing the appeal. en-us Wed, 15 Mar 2023 00:00:00 +0530 Wed, 07 Feb 2024 14:24:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=436552 The Court upheld the Tribunal's decision to apply Advance Pricing Agreement (APA) principles for benchmarking transactions for Assessment Year (AY) 2012-13, despite APA's statutory introduction in AY 2013-14. The Court found the Tribunal's approach appropriate, emphasizing the Transfer Pricing Officer's (TPO) role in ensuring Functions, Assets, and Risks (FAR) alignment with APA principles. The decision was supported by previous judgments allowing APA adoption for years not explicitly covered. The Court concluded that no substantial question of law arose, affirming the Tribunal's application of the law and closing the appeal. Case-Laws Income Tax Wed, 15 Mar 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=436552