Transfer Pricing – Initial burden is upon the assessee to prove the reasonableness of the method followed by the assessee-company

Cherokee India Pvt. Ltd. Vs. ITO ITAT Mumbai ITA. No. 825/Mum/2010 Assessment year: 2005- 2006 ORDER PER D. MANMOHAN, V.P. 1. Assessment made by the Assessing Officer under section 143 (3) of the Act read with section 92C(4) of the I.T. Act for the assessment year 2005- 2006, having been confirmed by the learned CIT(A), assessee is in appeal before us. Though several grounds were urged before us, all the grounds are directed against the correctness of the transfer pricing adjustment made by the TPO as against the profit/losses declared by the assessee under Transactional Net ...