Transfer Pricing – TPO can rely on ‘contemporaneous’ data even if not available at specified date – ITAT Bangalore

Kodiak Networks (India) Pvt. Ltd. Vs. ACIT (ITAT Bangalore)- As far as the data to be used by the TPO while determining the ALP was concerned, it is observed that it is covered by the provisions of rule 10D sub-rule 4 of the Income-tax Rules. Section 92 C provides that the arm’s length price in relation to an international transaction shall be determined by any of the methods being the most appropriate method having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors for computing the...