TPO must justify altering the previously accepted position on comparables

PCIT Vs Osram India Pvt. Ltd (Punjab and Haryana High Court) In PCIT Vs Osram India Pvt. Ltd., the Punjab and Haryana High Court addressed an appeal by the Revenue against an Income Tax Appellate Tribunal (ITAT) decision. The ITAT upheld the ruling of the Commissioner of Income Tax (Appeals) [CIT(A)], rejecting the findings of the Transfer Pricing Officer (TPO) in determining the Arm’s Length Price (ALP) for international transactions. The Revenue challenged this decision, asserting that the TPO had applied the relevant rules correctly by using data from the financial year in which the trans...