https://www.taxtmi.com/caselaws?id=446103 The ITAT Delhi ruled in favor of the assessee regarding a TP adjustment dispute. The AO made an addition for short term capital gain by adopting a different sale consideration than declared by the assessee, despite the TPO proposing no adjustment under Section 92CA(3). The AO substituted sale consideration based on subsequent year transactions without proper verification of assets. The tribunal held that under Section 92CA(4), the AO must compute Arm's Length Price in conformity with TPO's determination and cannot deviate without justification. The AO's interpolation of sale consideration figures was deemed impermissible under law, violating natural justice principles. The assessee's grounds were allowed. en-us Wed, 22 Nov 2023 00:00:00 +0530 Sat, 25 Nov 2023 06:02:51 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=446103 The ITAT Delhi ruled in favor of the assessee regarding a TP adjustment dispute. The AO made an addition for short term capital gain by adopting a different sale consideration than declared by the assessee, despite the TPO proposing no adjustment under Section 92CA(3). The AO substituted sale consideration based on subsequent year transactions without proper verification of assets. The tribunal held that under Section 92CA(4), the AO must compute Arm's Length Price in conformity with TPO's determination and cannot deviate without justification. The AO's interpolation of sale consideration figures was deemed impermissible under law, violating natural justice principles. The assessee's grounds were allowed. Case-Laws Income Tax Wed, 22 Nov 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=446103