https://www.taxtmi.com/caselaws?id=763065 The Tribunal's remand in transfer pricing proceedings was confined to fresh determination of arm's length price through internal comparison of profitability between associated-enterprise and unrelated-party transactions, after proper allocation of revenues and expenses to each segment. The Transfer Pricing Officer exceeded those directions by recomputing the net profit margin on an incorrect basis, substituting actual costs in the unrelated-party segment at the related-party segment level. The Delhi HC found no error in the Tribunal's treatment of that overreach and held that no substantial question of law arose, so the challenge to the Tribunal's order failed. en-us Fri, 02 Aug 2024 00:00:00 +0530 Thu, 12 Dec 2024 08:55:56 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=763065 The Tribunal's remand in transfer pricing proceedings was confined to fresh determination of arm's length price through internal comparison of profitability between associated-enterprise and unrelated-party transactions, after proper allocation of revenues and expenses to each segment. The Transfer Pricing Officer exceeded those directions by recomputing the net profit margin on an incorrect basis, substituting actual costs in the unrelated-party segment at the related-party segment level. The Delhi HC found no error in the Tribunal's treatment of that overreach and held that no substantial question of law arose, so the challenge to the Tribunal's order failed. Case-Laws Income Tax Fri, 02 Aug 2024 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=763065