TPO must justify arm’s length margin fixed by it

IN THE ITAT MUMBAI BENCH ‘K’ SITEL India (P.) Ltd. Versus Assistant Commissioner of Income-tax IT Appeal Nos. 3535 & 4073 (Mum.) of 2009 [Assessment year 2004-05] DECEMBER 5, 2012 ORDER 1. These are cross appeals by Assessee and Revenue against the order of the CIT (A)-32 Mumbai dated 27.02.2009. Assessee has raised five grounds in its appeal, whereas the Revenue has raised only one ground in its appeal. Assessee’s ground No.2 and Revenue’s appeal are with reference to the transfer pricing adjustment made by the TPO which was partly confirmed by the...