TE CONNECTIVITY INDIA PRIVATE LIMITED,BANGALORE vs. THE OFFICE OF THE DEPUTY COMMISSIONER OF INCOME-TAX, CIRCLE 7(1)(1), BANGALORE
In the result, the appeal of the assessee is partly allowed for statistical purposes
ITA 2346/BANG/2024[2021-22]Status: DisposedITAT Bangalore10 Oct 2025AY 2021-22
Bench: Shri Waseem Ahmed & Shri Keshav Dubey
For Appellant: Shri Darpan Kriplani, CAFor Respondent: Dr. KJ Dhivya, CIT (DR)
section 92C of the Act, read with Rule 10B of the Income-tax Rules, prescribes that the ALP of an international transaction must be determined using one of the prescribed methods i.e. CUP, RPM,
CPM, PSM, TNMM, or any other method notified. The statute does not permit the Revenue to determine ALP on an ad hoc basis. In the present
