Held that when the matter remanded to find out most appropriate method and then find out ALP of international transaction, selection of any of methods was open before TPO, who could reshuffle existing data or require assessee to make good deficiencies in existing data and proceed with determination of ALP of international transaction. Miscellaneous application to direct the TPO to adopt a particular method of accounting was rejected. (AY. 2009-10)
Carraro India (P.) Ltd. v. DCIT (2021) 188 ITD 915 (Pune)(Trib.)
S. 254(2) : Appellate Tribunal-Rectification of mistake apparent from the record-Transfer pricing-Arm’s length price-Most appropriate method-Application to Tribunal to direct the TPO to adopt a specific method was rejected. [S. 254(1), 92C]