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2012 (6) TMI 703 - AT - Income TaxTransfer pricing - Computation of arm's length price - related party transactions – Assessing Officer made reference to TPO to ascertain arm's length price - TPO selected four comparables and since arithmetic mean of operating profit margins of said comparables was higher than margin of assessee, he proposed an adjustment of Rs. 8.56 crores – Held that:- On instant appeal, it was seen that assessee was entitled to benefit of standard deduction of 5 per cent in matter of making transfer pricing adjustment - Further, proposition put forth by assessee that adjustment for ALP was to be made only in respect of transactions with associated enterprises instead of its entire turnover of trading segment was also found acceptable - on facts, impugned order passed under section 143(3), read with section 144C(13), was to be set aside and, matter was to be restored to file of Assessing Officer for disposal afresh – Matter remanded.
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