Transfer Pricing Adjustment Reference Invalid: No Prior Adjustments Over Rs. 10 Crore or Judicial Authority Support, Violating 2016 Guidelines.

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....TP Adjustment - Reference to TPO - none of the two conditions enshrined in the Instruction of 2016 were satisfied in as much as neither transfer pricing adjustment of more than ₹ 10 crore was made for an earlier year nor, as a sequitur there was any question of such transfer pricing adjustment having been either upheld by a judicial authority or pending in appeal - reference is invalid - AT....