TP Adjustment Set Aside for Failure to Prove Profit Shifting Under Section 80-IA(10)

Advertisement Imperial Jewels Vs Assessment Unit (ITAT Mumbai) The appeal arose from the final assessment order dated 27 September 2024 passed under Sections 143(3) read with 144C(13) for Assessment Year 2021-22. The assessee, engaged in the manufacture and export of studded jewellery through its SEEPZ-SEZ unit, challenged a transfer pricing adjustment of ₹38,49,450 and the consequential computation of deduction under Section 10AA. The assessee contended that it had neither entered into any international transaction with an Associated Enterprise under Section 92A nor any specified domesti...