2017 (7) TMI 812

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....ellant strenuously contends that the appellant is engaged in the business of merchant banking, stock broking and dealing in other securities and in providing related financial and advisory services. 4. According to the learned counsel, the matter was referred to the Transfer Pricing Officer (TPO) under Section 92CA of the Income Tax Act to compute the Arms Length Price (ALP) in relation to the international transactions. The TPO passed an order under Section 92CA(3) wherein the Transfer Pricing adjustment of Rs. 74,79,266/was made. Pursuant thereto, the Assessing Officer passed the assessment order in accordance with the order of the Transfer Pricing Officer making addition of Rs. 74,79,266/. The Commissioner of Income Tax (Appeals) [CIT....

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....e Arms Length Price along with price was calculated based on the aforesaid rates. No error was committed by the TPO inter alia the Assessing Officer. There was no reason for the CIT(A) and Tribunal to interfere. 5. Mr. Pardiwala, the learned Senior Counsel for the respondent submits that the TNMM adopted by the assessee was not accepted by the TPO nor by the Commissioner and the Tribunal. The Commissioner and the Tribunal accepted the CUP method for determination of the Arms Length Price. The adjustment was made by the Assessing Officer / TPO, the same has been considered. However, the CIT(A) found that the adjustment which is made by the Assessing Officer is improper and gave reasons for adjustment to be made. The CIT(A) was dealing wit....