https://www.taxtmi.com/caselaws?id=471204 Sections 92C and 92CA of the Income-tax Act, read with binding CBDT transfer-pricing instructions issued under section 119, allocate arm's-length price determination roles between the Assessing Officer and the Transfer Pricing Officer. Where the prescribed circumstances require a reference, the Assessing Officer cannot conduct a detailed examination of the international transaction price at the reference stage or determine the arm's-length price directly. Non-reference to the Transfer Pricing Officer breaches the mandatory instructions. Consequently, a transfer-pricing adjustment made directly by the Assessing Officer without the required referral procedure is invalid. en-us Tue, 07 Feb 2023 00:00:00 +0530 Tue, 25 Aug 2026 18:39:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=471204 Sections 92C and 92CA of the Income-tax Act, read with binding CBDT transfer-pricing instructions issued under section 119, allocate arm's-length price determination roles between the Assessing Officer and the Transfer Pricing Officer. Where the prescribed circumstances require a reference, the Assessing Officer cannot conduct a detailed examination of the international transaction price at the reference stage or determine the arm's-length price directly. Non-reference to the Transfer Pricing Officer breaches the mandatory instructions. Consequently, a transfer-pricing adjustment made directly by the Assessing Officer without the required referral procedure is invalid. Case-Laws Income Tax Tue, 07 Feb 2023 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=471204