Transfer Pricing – Scope of +/- 5% tolerance adjustment to ALP explained

INCOME TAX APPELLATE TRIBUNAL ITA No. 5890/Del/2010 Assessment Year: 2006- 07 M/s IHG IT Services (India) Vs. Income Tax Officer ORDER PER BENCH: This Special Bench was originally constituted under Section 255(3) of the Income-tax Act, 1961 by the Honorable President, Income Tax Appellate Tribunal, vide order dated 16th March, 2012, consisting of Shri G.E.Veerabhadrappa, President, Shri G.D.Agrawal, Vice President and Shri Rajpal Yadav, Judicial Member, inter alia, to consider and decide the following question:- “Whether prior to insertion of second proviso to Section...