TPO Must Use Appropriate Methods with Evidence to Determine Arm's Length Price, No Ad-Hoc Estimations Allowed.

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....If the Transfer Pricing Officer did not agree to the arm's length price shown by the assessee it was open for him to determine the arm's length price by applying one of the most appropriate methods being backed by supporting material. Without complying to the statutory provisions, the Transfer Pricing Officer certainly cannot determine the arm's length price on ad–hoc / estimation basis.....