Case Law Details
Case Name : Ms CLSA India Private Limited Vs DCIT (ITAT Mumbai)
Appeal Number : ITA No. 1182/Mum/2017
Date of Judgement/Order : 16/01/2019
Related Assessment Year : 2012-13
Courts :
All ITAT ITAT Mumbai
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Ms CLSA India Private Limited Vs DCIT (ITAT Mumbai)
ITAT Mumbai held that AD-Hoc Determination of Arm’s Length ALP) Price By Transfer Pricing Officer (TPO) Not Sustainable in Law.
FACTS –
Assessee is a subsidiary of Credit Lyonnais Securities Asia, Netherland. Return of assessee was selected for scrutiny and international transaction with its associated enterprise was referred to Transfer Pricing Officer (TPO) for determining Arm’s Length Price (ALP).
TPO determined the ALP making upward adjustment of INR 1,43,67,42,784 and accordingly AO made addition of the same.
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