Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2012 (10) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2012 (10) TMI 1029 - AT - Income TaxDisallowance of communication, travel and onsite expenses - Determination of Arms Length Price for international transactions - Held that:- decision of the Hon’ble Karnataka High Court in the case of Tata Elxsi and the CIT(A) has followed the same in granting relief from disallowance u/s 10A to the assessee - Decided in favor of assessee Held that:- No bench marking for super profit making companies is prescribed by the law - as long as two companies are functionally similar, they are to be considered as comparables - The factor of loss in the parent company would not be a guiding factor for making any adjustment to the ALP of the international transaction - If the parent company is making any losses, then the said company to claim the losses in accordance with the laws of the country in which it is taxable - the working capital adjustment is accordingly allowed for statistical purpose - Partly in favor of revenue
|