TPO fails to Apply Industry Filter while Determining ALP of Interest: ITAT Deletes addition

DCIT Vs DLF Urban Pvt. Ltd. (ITAT Delhi) The Income Tax Appellate Tribunal (ITAT) in Delhi recently ruled in the case of DCIT vs. DLF Urban Pvt. Ltd., addressing key issues in transfer pricing adjustments. The crux of the case revolved around the Arm’s Length Price (ALP) determination for the interest on loans involving Compulsorily Convertible Debentures (CCDs) and Optionally Convertible Debentures (OCDs). The ITAT’s decision to dismiss the appeal filed by the Deputy Commissioner of Income Tax (DCIT) was based on the Transfer Pricing Officer’s (TPO) failure to apply the appropri...