APA with CBDT Binding; TPO Must Align ALP with APA Terms, Not Override: ITAT Kolkata

DIC Fine Chemicals Pvt. Ltd. Vs DCIT (ITAT Kolkata) The case before the Income Tax Appellate Tribunal Kolkata involved an appeal by the assessee against the final assessment order passed under Sections 143(3), 144C(13), and 144B of the Income Tax Act, 1961 for Assessment Year (AY) 2021–22. The assessee, engaged in manufacturing and exporting sheet-fed ink as part of an international group, had entered into multiple international transactions with its associated enterprises (AEs), including purchase of raw materials, capital goods, sale of finished goods, and cross-charged expenses. These tra...