https://www.taxtmi.com/caselaws?id=757431 An Additional Commissioner could validly function as a Transfer Pricing Officer where the statutory designation and Board authorisation scheme covered the post, so the jurisdiction challenge failed. In section 14A read with Rule 8D, the interest component was deleted because own funds exceeded investments, while the administrative component was restricted to investments yielding exempt income. Selective internal CUP benchmarking for vehicle exports was rejected, and the related adjustment was deleted. Hispano Carrocera, S.A. was treated as an associated enterprise; the loan pricing issue was remanded for fresh examination, while the property purchase adjustment and notional rent on the leased property were deleted. Relief was granted on excess interest, the leasehold land claim was sent back for limited verification, and the limitation challenge failed. en-us Mon, 05 Feb 2024 00:00:00 +0530 Tue, 27 Aug 2024 20:55:34 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=757431 An Additional Commissioner could validly function as a Transfer Pricing Officer where the statutory designation and Board authorisation scheme covered the post, so the jurisdiction challenge failed. In section 14A read with Rule 8D, the interest component was deleted because own funds exceeded investments, while the administrative component was restricted to investments yielding exempt income. Selective internal CUP benchmarking for vehicle exports was rejected, and the related adjustment was deleted. Hispano Carrocera, S.A. was treated as an associated enterprise; the loan pricing issue was remanded for fresh examination, while the property purchase adjustment and notional rent on the leased property were deleted. Relief was granted on excess interest, the leasehold land claim was sent back for limited verification, and the limitation challenge failed. Case-Laws Income Tax Mon, 05 Feb 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=757431