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 DECIDED ON July 1, 2010 RELEVANT PARAGRAPHS 66. According to the TPO, Maruti did not tell him how much royalty, out of the total royalty of Rs.198.6 crores paid by it to Suzuki in the year 1994-95, was tow...