TPO cannot follow a method which is not authorized by the Income Tax Act or the Income Tax Rules to determine the arm’s length price

ITAT Ruling: The Tribunal held that the Transfer Pricing Officer cannot exceed his limitation by following any method to determine the arm’s length price which is not authorised by the Income Tax Act or the Income Tax Rules Facts: CA Computer Associates Pvt. Ltd. (assessee) was incorporated during the year 1998 and was a 100 % subsidiary of Computer Associates International Inc. USA (CA – USA). The assessee was primarily engaged in the business of (i) licensing mainframe mid range and system infrastructure software products of CA Management Inc. USA (CAMI – USA); (ii) softw...