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Informative

Assessee’s Foreign AE not used as Tested Party in Previous Years: Delhi HC dismisses Challenge to Transfer Pricing Addition

Update / Judgement Date

03 Nov 2024

Source

Taxscan

Author

Team — WCP Legal Desk

Reading Time

1 min read

Appeal Against OrderGST

The Delhi High Court dismissed a challenge to a transfer pricing addition where the assessee’s foreign associated enterprise (AE) was not used as the tested party in previous years. The court upheld the transfer pricing adjustment, emphasizing the importance of consistency in applying transfer pricing rules. This ruling provides guidance on the selection of tested parties in transfer pricing cases.