The Tribunal for the Assessments year 2013-14, applied the TNMM method. For the assessment year 2015-16, the Assessing Officer applied the operating margin method. The assessee has filed the writ against the assessment order. Dismissing the petition the Court held that the challenge to the assessment order is premature. The assessee has the option to approach the DRP or an appeal. The writ petition was dismissed. (AY. 2015-16)
Bonfiglioli Transmission (P) Ltd. v. Dy. CIT (2021) 203 DTR 329 / 321 CTR 726/(2023) 451 ITR 501 (Mad.)(HC)
S. 92C : Transfer pricing-Arm’s length price-Computation-TNMM-Alternative remedy-Writ to quash the assessment order-Writ is held to be not maintainable. [S. 92CA, Art. 226 ]