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Transfer Pricing ALP Adjustment Remanded for Fresh FAR Analysis of Comparables: ITAT Delhi
Case Law Details
- Case Name
- A.HARTRODT India Private Limited Vs DCIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Delhi
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A.HARTRODT India Private Limited Vs DCIT (ITAT Delhi)
The assessee appealed against the assessment order dated 24.10.2024 passed under Sections 143(3), 144C(13) and 144B for AY 2021-22, whereby an addition of Rs.1,31,28,013 was sustained on account of arm’s length price (ALP) adjustment under Section 92C pursuant to the directions of the DRP. The dispute related to international transactions involving provision and availing of freight and forwarding services. The assessee had benchmarked the transactions under the Transactional Net Margin Method (TNMM) using OP/OC as the pro...
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