Thursday, July 14, 2011

TPO cannot suo moto take cognizance of any international transaction for su

TPO cannot suo moto take cognizance of any international transaction for suggesting adjustment in arm's length price

Income-tax : Section 92CA - Transfer Pricing - As per section 92CA(1), TPO can suggest adjustment on international transaction entered into by an assessee with its associate enterprises which were sent to him for computation of arm's length price by Assessing Officer, suo moto, he cannot take cognizance of any international transaction for suggesting adjustment in arm's length price

l Section 92CA nowhere reveals that TPO can take any transaction suo moto for verification and then suggest necessary adjustment. - [2011] 10 taxmann.com 88 (Delhi - ITAT)

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