AO Cannot Override TPO; Rs. 33.95 Cr TP Addition Set to Nil: ITAT Delhi

Richemont India Private Limited Vs DCIT (ITAT Delhi) When TPO Says Nil, AO can’t add – AO overlooked TPO’s Nil adjustment – Rs.33.95 Cr Reduced to Nil -ITAT Delhi Orders AO to Amend Assessment Assessee filed appeal against the final assessment order dated 18.06.2024 passed in compliance to DRP directions. It was submitted that pursuant to DRP’s order u/s 144C(5) dated 21.05.2024, the TPO on 18.06.2024 recomputed transfer pricing adjustment at Nil as against Rs.33.95 crore proposed earlier in TPO’s order dated 28.09.2023. However, AO passed final assessment on the same date ...