Held that the Authorities justified in adopting combined accounts approach and confining addition to export segment-Functional similarity. Low turnover. Matter remanded. Assessing Officer bound to follow Dispute Resolution Panel’s Direction (AY.2014-15)
Tasty Bite Eatables Ltd. v. ACIT (2021) 89 ITR 699 / 214 TTJ 643 / 205 DTR 289 (Pune)(Trib.)
S. 92C : Transfer pricing-Arm’s length price-Comparable-Authorities justified in adopting combined accounts approach and confining addition to export segment-Functional similarity-Low turnover-Matter remanded-Draft Assessment order-Assessing Officer bound to follow Dispute Resolution Panel’s Direction. [S. 144C]