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TPO to consider both external and internal comparables to determine ALP
Case Law Details
- Case Name
- California Software Co. Ltd. Vs Assistant Commissioner of Income-tax (ITAT Chennai)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2007-08
- Courts
- All ITAT, ITAT Chennai
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IN THE ITAT CHENNAI BENCH ‘A’
California Software Co. Ltd.
Versus
Assistant Commissioner of Income-tax
Dr. O.K. Narayanan, Vice-President
and Challa Nagendra Prasad, Judicial Member
IT Appeal No. 1842 (Mds.) of 2011
[Assessment year 2007-08]
August 27, 2012
ORDER
O.K. Narayanan, Vice-President
This is a Transfer Pricing (TP) appeal. The assessment year is 2007-08. It is filed by the assessee. It is directed against the order of the assessing authority passed under section 143(3), read with sections 92CA and 144C(5) of the Income-tax Act, 1961. The Transfer Pricing Officer (TPO) has...
