TPO duty bound to determine ALP by following any one of prescribed methods

Firemenich Aromatics Production (India) Pvt. Ltd. Vs ACIT (ITAT Mumbai)

We find that IS charges were paid by the assessee for obtaining access to ERP software and for regular recurrent services and such charges were paid in earlier years also. In AY 2012-13, similar adjustment proposed by Ld. TPO was deleted by coordinate bench on the premises that Ld. TPO was duty bound to determine ALP by following any one of the prescribed methods and determination of ALP on adhoc basis could not be sustained. It was also observed that the assessee had submitted subs

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