Wipro Enterprises (P.) Ltd v. Dy.CIT (2024) 298 Taxman 155 (Karn)(HC)

S. 92CA : Transfer pricing-Reference to Transfer Pricing Officer-Arm’s Length price-Avoidance of tax-Order passed without considering relevant statutory provisions as will as judgements of various High Courts-Matter remanded to back to TPO for reconsideration in accordance with law.[Art. 226]

Against the order of TPPO the assessee  writ petition, and  submitted that TPO committed an error in passing TP order without considering or appreciating relevant statutory provisions as well as judgment of various High Courts relied upon by assessee-Whether since said judgments relied upon assessee were rendered prior to impugned order, and TPO also did not take into account relevant statutory provisions before passing impugned order, it would be just and appropriate to remit matter back to TPO for reconsideration afresh in accordance with law. Matter remanded. (AY. 2020-21)