Taxpayer Disputes ALP Adjustment; CIT(A) Criticized for Deviating from Transfer Pricing Norms Under Income Tax Act.

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....Transfer pricing adjustment - determination of ALP - Not only changing the tested party from the assessee to its AE, the CIT (Appeals) has also selected a domestic company as a comparable to the AE of the assessee. Therefore the entire exercise of determining the ALP by the CIT (Appeals) is contrary to the provisions of transfer pricing under the I.T. Act. - AT....