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2014 (11) TMI 431 - ITAT PANAJITransfer pricing adjustment - International transaction of purchase of concrete pump units – Held that:- The assessee has submitted the details in respect of materials, components or parts purchased by the assessee from its AE during the financial year 2007-08 and corresponding particulars of transactions is given in ‘Annexure-1’ - the TPO has no occasion to verify this all documentary evidence - the assessee has produced all these documentary evidence and the documentary evidence shows that if the TPO consider that the assessee has to incur the higher costs on account of higher import duty - where there is imported content of raw material and if the price variation is due to imported raw materials, if it is the first year of operation it will have impact for deciding the arms length price but in that situation imported contents of raw materials which has substantially come down in succeeding year has to be considered while deciding the transfer pricing arms length price and matter was restored to the AO - the issue should be set aside to the file of TPO with the direction to eliminate the difference, if any – Decided in favour of assessee. Depreciation on computer peripherals on the UPS @ 60% – Held that:- The UPS system is designed special for computers for both low and high users and it forms part of entire information technology infrastructure of the company - The UPS is entitled for depreciation @ 60% as decided in CIT vs. BSES Rajdhani Powers Ltd. [2010 (8) TMI 58 - DELHI HIGH COURT] - assessee company is eligible for depreciation @ 60% on UPS – Decided in favour of assessee.
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