https://www.taxtmi.com/caselaws?id=456896 ITAT Mumbai held that section 144C procedure for draft assessment orders applies from 01/10/2009, following Andhra Pradesh HC Division Bench over Madras HC Single Bench decision. Assessment year 2009-10 draft order issued 28/03/2013 and final order 26/02/2014 were within limitation. Transfer pricing adjustments should be limited to international transactions with Associated Enterprises, not entire manufacturing turnover. Matter remanded to AO for proper comparison with export segment of comparables. Purchase expense additions sustained only where assessee failed to substantiate transactions, as DRP had already verified parties and considered evidence. en-us Mon, 18 Jul 2022 00:00:00 +0530 Fri, 23 Aug 2024 20:33:33 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=456896 ITAT Mumbai held that section 144C procedure for draft assessment orders applies from 01/10/2009, following Andhra Pradesh HC Division Bench over Madras HC Single Bench decision. Assessment year 2009-10 draft order issued 28/03/2013 and final order 26/02/2014 were within limitation. Transfer pricing adjustments should be limited to international transactions with Associated Enterprises, not entire manufacturing turnover. Matter remanded to AO for proper comparison with export segment of comparables. Purchase expense additions sustained only where assessee failed to substantiate transactions, as DRP had already verified parties and considered evidence. Case-Laws Income Tax Mon, 18 Jul 2022 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=456896