TPO cannot be asked to establish motive behind transfer of profit before ALP determination

IN THE ITAT BANGALORE BENCH ‘A’ 24/7 Customer.Com (P.) Ltd. Versus Deputy Commissioner of Income-tax IT APPEAL NO. 227 (BANG.) OF 2010 [ASSESSMENT YEAR 2004-05] NOVEMBER 9, 2012 ORDER Jason P. Boaz, Accountant Member – This appeal by the assessee is directed against the order of the Commissioner of Income Tax (Appeals)-IV, Bangalore dt.30.11.2009 for Assessment Year 2004-05. 2. The facts of the case, in brief, are as under : 2.1 The assessee, an Indian Company engaged in the business of providing call centre services exclusively to its Associated Enterprise (...