TPO can compute ALP after giving assessee opportunity to produce evidence in support of ALP computed by him

Cross-border transaction- TPO/AO, before he determines arm’s length price in relation to income from an international transaction, needs to give appropriate notice to assessee, giving him an opportunity to produce evidence in support of arm’s length price computed by him.

HIGH COURT OF DELHI

Maruti Suzuki India Ltd. Vs. Addl. CIT Transfer Pricing Officer

APPEAL NO: W. P. (C) 6876/2008

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