Ipolicy Network (P) Ltd. vs Income Tax Officer
Whether the benefit of safe harbour of +/- 5% under proviso to section 92C(2) of the Income Tax Act 1961 (pre-amendment) is available to the assessee when the Transfer Pricing Officer (TPO) determined Arm's Length Price (ALP) using multiple comparables --- Held Yes, as the difference between ALP determined by TPO and price received by assessee was within 5% margin, requiring deletion of transfer pricing adjustment.
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