Dismissing the appeal of the assessee the Tribunal held that, Transfer pricing risk parameter, fell under para 3.2 of circular dated 10-3-2016 which required reference to TPO by Assessing Officer mandatorily. Accordingly revision is held to be justified. (AY. 2015 -16)
Varian Medical Systems International India (P.) Ltd. v. PCIT (2019) 174 ITD 721/ 199 TTJ 118 / 177 DTR 162(Mum.)(Trib.)
S. 263 : Commissioner-Revision of orders prejudicial to revenue -Transfer pricing officer-Transfer pricing risk parameter, fell under para 3.2 of circular dated 10-3-2016 which required reference to TPO by Assessing Officer mandatorily – Revision is held to be justified. [S. 92CA]