Arm's length price". Adjustments are made in the controlled price by determining Arm's length price through different methods. This exercise ... Transfer Pricing Officer.
(7) The Transfer Pricing Officer may, for the purposes of determining the arm's length price under this section, exercise
attached with the return. However, the issue of determination of 'Arms Length price' was not referred to the Transfer Pricing Officer as required ... Length Price. It is therefore mandatory that in case of every international transaction, the price charged as per books must be shown to be Arm
result of the scrutiny proceedings before
the Transfer Pricing Officer, arm's length price adjustments were recommended in
respect of (i) interest on loans ... arm's length interest on the said transaction. As regards the claim of
the assessee that no arm's length price
officer/DRP erred on facts and in law in
determining the arms length price of the international
transactions of payment of corporate charges amounting ... Transfer Pricing
Officer (in short "TPO") to determine the arms length price of the
10 ITA Nos.1308/Del/2015; 4913 & 5026
account of adjustment in the Arm's length price tinder the provisions of Section 92CA(3) of the Act for services rendered ... determining the sale price has not computed (he price of international transaction at arm's length. It is common place that profit in this
length price in connection with its
international transaction;
5. erred in upholding the adoption of Comparable Uncontrolled Price ('CUP') determining the
arm ... length price
in relation to international transaction, without appreciating that the scope of transfer
pricing adjustment is restricted to computing the arm's length
said order, main grievance of
the assessee is against the arm's length price adjustment of Rs 1,588.85 crores made by the
Assessing ... first. Grievances raised by the appellant, with respect to this
arm's length price adjustment, are as follows:
ITA No. 565/Ahd/17
Assessment
regard to first two categories.
Appellant followed TNMM method for calculating arms length price
which was changed by the assessing officer to CUP method ... below-
"in so far as the method of variation of arms length prices is concerned,
the provisions of the act are very clear
arm's length price
himself. Thus, the jurisdiction of the Transfer
Pricing Officer is limited and restricted to
computing arm's length price ... arm's
length action.
8.21 Further, as per section 92(3) of the Income-
tax Act, any computation of arm's length price
arrive at the most precise approximation of arm's length
conditions, the arm's length principle should be applied on a transaction ... Arm's Length
wherein the assessee followed the same economic analysis to determine the Arm's
Length Price.
In view of the aforesaid
