Punjab & Haryana HC deletes Arm’s Length Price in absence of Justification in Comparables used During ALP Determination [Read Order]
It was observed that once the TPO himself has not accepted the said comparable which were considered for assessment proceedings in question while examining subsequent assessment proceedings,the court cannot allow the inclusion of such comparables for the first time
The Punjab & Haryana High Court in a recent case deleted the Arm’s Length Price ( ALP ) in absence of justification in comparables used during ALP determination. It was held that Revenue Department must establish compelling reasons for taking departure from the comparables selected by him in previous assessment years if he opts so,…
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