Deriving Arm’s Length Price without resorting to any prescribed method is unjustifiable

Marks & Spencer (India) Pvt. Ltd. Vs ACIT (ITAT Delhi) ITAT Delhi held that deriving Arm’s Length Price without resorting to any method prescribed as per the Income Tax Rules is unjustifiable. Accordingly, TPO/ AO directed to determine Arm’s Length Price. Facts- M&S India is a subsidiary of Marks and Spencer Investments Pte. Ltd. engaged in the wholesale business of procuring and selling branded apparels and accessories including leather products and toiletries. Under the trading business of the Assessee, it procures branded apparels and accessories from third party suppliers who m...