Tribunal remanded to the Transfer Pricing Officer with a direction to consider the fresh search of the comparables by the assessee. The assessee was to submit the complete search along with accept/reject matrix and the computation of the margin of the transactional net margin method before the Transfer Pricing Officer and the Transfer Pricing Officer may verify it and after giving proper opportunity of hearing to the assessee may compute the correct margin and consequent adjustment.( AY.2012-13)
USG India Pvt. Ltd. v. ACIT (2021)85 ITR 71 (SN)(Delhi) (Trib)
S. 92C : Transfer pricing – Arm’s length price – Transactional Net Margin Method —Matter remanded to transfer pricing officer to consider fresh search of comparables. [ S.92C(3) ]