https://www.taxtmi.com/highlights?id=72905 TP Adjustment - TPO rejected the ‘entity-level’ benchmarking done by assessee, instead made ‘unit-level’ comparison i.e. PLI of each unit was compared with the PLI of external comparables - 'principle of res judicata' OR ‘principle of consistency' - the uniform rate agreed by assessee with AEs is certainly a rate at entity-level which has no connection or linkage with individual units. - AT en-us Sat, 04 Nov 2023 23:22:48 +0530 Sat, 04 Nov 2023 23:22:48 +0530 TaxTMI RSS Generator https://www.taxtmi.com/highlights?id=72905 TP Adjustment - TPO rejected the ‘entity-level’ benchmarking done by assessee, instead made ‘unit-level’ comparison i.e. PLI of each unit was compared with the PLI of external comparables - 'principle of res judicata' OR ‘principle of consistency' - the uniform rate agreed by assessee with AEs is certainly a rate at entity-level which has no connection or linkage with individual units. - AT Highlights Income Tax Sat, 04 Nov 2023 23:22:48 +0530 https://www.taxtmi.com/highlights?id=72905