The DRP provided directions to rework the transfer pricing adjustment, but the Assessing Officer retained the same adjustment in the final assessment order. The assessee challenged the validity of the final assessment order, arguing a violation of provisions of section 144C (10) r.w.s. 144C (13) of the Income-tax Act.The Tribunal quashed the transfer pricing adjustment, emphasizing that the AO’s failure to adhere to the DRP’s directions rendered the final assessment order invalid.(AY. 2012-13)
Tata Power Solar Systems Ltd. v. DCIT (2023) 200 ITD 226 (Bang (Trib.)
S. 144C : Reference to dispute resolution panel-Transfer pricing-Draft assessment order-Failure to give effect to the direction of DRP-Order was quashed.[S. 144c(10) 144C(13)]