Transfer Pricing – Comparable rejected by TPO without giving cogent reasons must be presumed to be comparable and DR cannot argue to the contrary

ACIT vs. Maersk Global Service Centre (ITAT Mumbai) -The Special Bench of the Tribunal in Mahindra & Mahindra Limited Vs. DCIT [(2009) 122 TTJ (Mum.) (SB) 577] has laid down the proposition to the effect that the Departmental Representative has no jurisdiction to go beyond

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