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Sec. 92C & 144C of Income Tax Act, 1961 - Transfer pricing - Neither the ALP adjustments can be equated with disallowances of expenses, even though effect may be same, nor the TPO has the authority to disallow the expenses. Clearly, the impugned ALP adjustments are vitiated in law for this short reason alone. In any case, the observations with respect to the lack of evidence in support of the benefits is based on sweeping generalizations and is incapable of sustaining legal scrutiny. - HAMON COOLING SYSTEMS PVT LTD V/s DEPUTY CIT -  185 ITD 023 (ITAT-MUMBAI)