Transfer PricingArticle·22 April 2026
Invalid TP Directions
By J the App
Executive Summary
The Tribunal held that directions issued earlier to the DRP were procedurally flawed since the DRP was not a party to the appeal.
However, since the DRP failed to comply with such directions in substance, the Tribunal corrected the irregularity by directing exclusion of five comparables and recomputation of ALP.
The assessment order was upheld otherwise.
Issues for Determination
1. Whether the assessment order passed pursuant to ITAT directions is invalid due to improper ...
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