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Section 143(3)2

PAREXEL INTERNATIONAL SERVICES INDIA PVT.LTD,,CHANDIGARH vs. ACIT,CIRCLE-5(1),(NEAC), CHANDIGARH

In the result, the appeal of the Assessee is partly allowed

ITA 129/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh28 Oct 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Reuben Mathew Jacob, Addl. CIT, Sr. DR

Section 143(3)Section 234BSection 271(1)(C)

Transfer Pricing Study was illegally disregarded and ignored. Further, though the ld. DRP initially upheld the CUP in principle, it upheld the CPM, as applied by the TPO, and it went on to ultimately make the TNMM the basis for the adjustment to determine the arm’s length price of the transaction. It also has rightly been called in question