Onus is on assessee to submit relevant data which must be examined by the revenue for ALP determination by applying prescribed methods

Advertisement Citation : M/s Hinduja TMT Ltd. [2010-T11-18-ITAT-MUM-TP] Court : Mumbai Bench of Income Tax Appellate Tribunal The Mumbai Bench of Income-tax Appellate Tribunal (“the Tribunal”), in its recent ruling in the case of M/s Hinduja TMT Ltd. [2010-T11-18-ITAT-MUM-TP]  , has held that the onus is on the assessee to prove the arm’s length nature of its international transactions with associated enterprises. In this regard, the uncontrolled comparable data as well as other relevant details submitted by the assessee must be examined by the Revenue. Arm’s length...