https://www.taxtmi.com/caselaws?id=762970 ITAT Cuttack remanded a transfer pricing case involving specified domestic transactions back to AO for re-examination. The assessee claimed CUP method was most appropriate but failed to provide detailed working or calculations to support this position before CIT(A). Since assessee only provided services to one party and had no independent comparable transactions, CUP method application was questionable. The Tribunal found CIT(A) deleted the adjustment without proper consideration of ALP determination methodology. Matter remanded to TPO for fresh determination using most suitable method with adequate opportunity for assessee to be heard. Revenue's appeal allowed for statistical purposes. en-us Thu, 25 Jul 2024 00:00:00 +0530 Tue, 10 Dec 2024 12:33:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=762970 ITAT Cuttack remanded a transfer pricing case involving specified domestic transactions back to AO for re-examination. The assessee claimed CUP method was most appropriate but failed to provide detailed working or calculations to support this position before CIT(A). Since assessee only provided services to one party and had no independent comparable transactions, CUP method application was questionable. The Tribunal found CIT(A) deleted the adjustment without proper consideration of ALP determination methodology. Matter remanded to TPO for fresh determination using most suitable method with adequate opportunity for assessee to be heard. Revenue's appeal allowed for statistical purposes. Case-Laws Income Tax Thu, 25 Jul 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=762970