Analysis of ITAT Mumbai Judgment - Transfer Pricing Adjustment Dispute: Period of limitation u/s 144C

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....een taxpayers and tax authorities regarding the pricing of transactions between related entities. These disputes play a critical role in determining the taxable income of multinational corporations. In this article, we will analyze a recent judgment by the Income Tax Appellate Tribunal (ITAT) Mumbai, which addresses various issues related to transfer pricing adjustments. Background: The case hea....

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....pellant is that the assessment order passed on August 1, 2022, is barred by limitation. The appellant argued that as per Section 144C(13) of the Income Tax Act, the order should have been passed within one month from the end of the month in which the directions from the Learned Dispute Resolution Panel (DRP) were received. The directions from the DRP were issued on June 14, 2022, and the appellant....

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....ble companies with margins ranging from 2.80% to 10.84%. The appellant argued that its margin fell within the range of the margins of comparable companies, justifying the arm's-length pricing. However, the Transfer Pricing Officer (TPO) examined the comparability study and raised questions about the exclusion of three comparable companies and the inclusion of non-functionally comparable compa....