TPO to consider both external and internal comparables to determine ALP

IN THE ITAT CHENNAI BENCH ‘A’ California Software Co. Ltd. Versus Assistant Commissioner of Income-tax Dr. O.K. Narayanan, Vice-President and Challa Nagendra Prasad, Judicial Member IT Appeal No. 1842 (Mds.) of 2011 [Assessment year 2007-08] August 27, 2012 ORDER O.K. Narayanan, Vice-President This is a Transfer Pricing (TP) appeal. The assessment year is 2007-08. It is filed by the assessee. It is directed against the order of the assessing authority passed under section 143(3), read with sections 92CA and 144C(5) of the Income-tax Act, 1961. The Transfer Pricing ...