ITAT Remands TP Adjustment as AE Transaction ALP Was Computed Using Incorrect Entity-Level Method

Delval Flow Controls Private Limited Vs DCIT (ITAT Pune) The appeal before the Income Tax Appellate Tribunal (ITAT), Pune, challenged the final assessment order dated 16 January 2017 passed under Sections 143(3) read with 144C(13) of the Income-tax Act, 1961 for Assessment Year 2012-13. The sole issue concerned the confirmation of a transfer pricing adjustment of ₹1,03,98,000. The assessee was engaged in manufacturing butterfly valves, actuators, and ball valves used in the oil, gas, and petrochemical industries. It filed its return declaring total income of ₹4.06 crore and reported intern...