TPO may adopt CUP method for unexplained part of transactions

Brief of the Case

Delhi High Court held In the case of Denso India Limited vs. CIT that there can be no dispute that the AO would normally accept the figures given in TP report, if they do not call for his interference. However, his job also extends to critically evaluating materials and in cases which do require scrutiny, go ahead and do so. The factual discussion in this case clearly reveals that the assessee chose to import components not from the manufacturer (which was an AE) but an intermediary. N

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