In the result, the appeal filed by the Assessee is hereby dismissed
Bench: Shri Waseem Ahmed (Accountant Member), Shri T.R. Senthil Kumar (Judicial Member)
92E of the Act on international/domestic transactions. Therefore the case was referred to Transfer Pricing Officer for determination of Arm’s Length Pricing u/s. 92CA of the Act. The Ld. TPO determined the Arm’s Length Price of the specified domestic transactions and recommended an upward adjustment of Rs. 1,89,74,894/- vide order dated 31-10-2017. After