Held that the Transfer Pricing Officer had the authority to call for complete information of the transactions of import of raw materials and export of finished goods from the customs authorities including invoices thereof showing details of geography and volume. The Transfer Pricing Officer may also remove the related-party transactions from the relevant information. Therefore, it was appropriate to restore the matter to the Transfer Pricing Officer/Assessing Officer to compare the TIPS data with the international transactions of the assessee using the comparable uncontrolled price method of comparability as the most appropriate method. If this method failed, the Transfer Pricing Officer could explore another method including the transactional net margin method. Matter remanded. (AY. 2015-16)
Dow Chemical International P. Ltd. v. ITO (2022)100 ITR 82 (Mum)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Most Appropriate Method-Matter remanded. [S. 92D]