Arm's Length Price Determined by Transfer Pricing Officer Must Follow Legal Authority Under Article 265 for Fair Taxation.

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....TP Adjustment - determination of Arms Length Price by TPO - MAM selection - No tax can be levied without the authority of law as mandated by Article 265 of the Constitution of India. Similarly, the exchequer should not be deprived from its legitimate tax due. In our view, the assessee would not be prejudiced in setting-aside proceeding, if they have merit in their favour. - AT....