AVINEON INDIA P. LTD. vs DEPUTY COMMISSIONER OF INCOME TAX
Whether the Transfer Pricing Officer (TPO) and Dispute Resolution Panel (DRP) erred in rejecting segmental data, applying ALP at entity level instead of restricting to AE transactions, and selecting inappropriate comparables for benchmarking international transactions under Section 92CA of the Income Tax Act, 1961? --- Held: Yes, in part. The Tribunal directed the AO/TPO to consider segmental data, restrict adjustments to AE transactions only, and exclude certain comparables with extraordinary events or supernormal profits.
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