ITAT: Invoking provisions of sec 92 (pre 2002) not justified where assessee's transactions held to be at arm's length

Invoking provisions of sec 92 (pre 2002) not justified where no discrepancy was found in transaction records maintained with customs authorities and transactions of assessee are held to be at

Jul 19, 2011

HC: DRP Procedure not applicable in the absence of transfer pricing adjustment

Indian company in whose case no TP adjustment proposed, not ‘eligible assessee’ u/s. 144C; DRP procedure not applicable to such assessee; Arguments on availing extended time-limit for completing assessment left

Jul 19, 2011

AAR: TP provisions not applicable in absence of liability to pay tax

Transfer pricing provisions not attracted if assessee's income not subject to tax in India: AAR

Jul 19, 2011

ITAT: Matter remanded in view of non-compliance of legal provisions by TPO as well as assessee

Matter remanded back to files of AO, where both TPO and assessee failed to comply with the provisions of the IT Act and Rules

Jul 19, 2011

ITAT: While determining ALP, weighted average to be applied instead of simple average

Use of weighted average preferred over use of simple average for computation of ALP

Jul 19, 2011

ITAT: Transfer pricing study conducted by TPO to be made available to assessee before making adjustment

TPO's order set aside, where TPO carried out his own research and relied on data which was not made available to the assessee

Jul 19, 2011