https://www.taxtmi.com/caselaws?id=750964 The HC held that the AO cannot make transfer pricing adjustments beyond the ALP determined by the TPO under Section 92CA. The AO must refer international transactions selected for scrutiny to the TPO, and compute total income strictly in conformity with the TPO's ALP determination. The AO's unilateral addition related to the demerger, without TPO's determination or hearing to the assessee, was held impermissible and beyond the AO's jurisdiction. The impugned order was quashed for violating the statutory mandate, and the writ petition was allowed. en-us Mon, 01 Apr 2024 00:00:00 +0530 Fri, 25 Jul 2025 16:46:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=750964 The HC held that the AO cannot make transfer pricing adjustments beyond the ALP determined by the TPO under Section 92CA. The AO must refer international transactions selected for scrutiny to the TPO, and compute total income strictly in conformity with the TPO's ALP determination. The AO's unilateral addition related to the demerger, without TPO's determination or hearing to the assessee, was held impermissible and beyond the AO's jurisdiction. The impugned order was quashed for violating the statutory mandate, and the writ petition was allowed. Case-Laws Income Tax Mon, 01 Apr 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=750964