It is mandatory for assessee, to follow one of prescribed methods and demonstrate that international transactions, entered into by it, with an associated enterprise, are at Arms Length Price

ORDER

PER J. SUDHAKAR REDDY, AM :-

These are cross’ appeals directed against the order of learned CIT(A)-XVII, Mumbai dated 23.1.2006 for A.Y. 2002-03.

2. Facts in brief :

The assessee is a partnership firm and in the business of import, manufacture and export of diamonds and Jewellery. During the year, the assessee has shown export sale of polished diamonds and claimed deduction u/s. 80HHC. The assessee also filed an Audit Report in the Form No. 3CEB. The Assessing Officer referred the case to the Transfer Pricing Officer (TPO) for determination of Arms Length Price (ALP) u/s. 92CA(3). TPO vide her order dated 9.3.2005 brought out the fact at paragraph 3&4 of her order, which is extracted for ready references :-

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