TPO cannot reject TP method adopted by assessee on the ground that the comparables are wrongly chosen

TPO cannot reject TP method adopted by assessee on the ground that the comparables are wrongly chosen. Further the ALP has to be determined with respect to an international transaction and not at an entity level Star Diamond Group Vs. Dy. Director of Income Tax (Mumbai Bench), ITA No: 3923/Mum/2008 Executive Summary The Mumbai bench of the Income Tax Appellate Tribunal (Tribunal) recently pronounced its ruling in the case of branch of Star India Diamond Co. (Belgium) N.V. (Taxpayer), on transfer pricing issues arising from import of rough diamonds by the Taxpayer from its Associated enterprise...