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2017 (5) TMI 1636 - ITAT PUNETPA - ALP determination - selection of MAM - DRP rejecting the CUP method adopted by TPO - Appropriateness of the TNMM method - Held that:- As decided in assessee;s own case in earlier years [2014 (5) TMI 1066 - ITAT PUNE] we find in principle the facts are the same. In those years too, Transfer Pricing adjustments were made to the transactions with Associated Enterprises with reference to the Export of goods and Import of the raw materials. Appropriateness of the TNMM method was also the issue in those years. Tribunal decided the issue in favour of the assessee and dismissed the appeal of the revenue on those issues. After hearing both the sides and perusing the contents of the DRP, we are of the opinion that the order passed by the DRP with reference to the most appropriate accounting method for TP study, is fair and reasonable and same does not call for any interference. Accordingly, the ground raised by the Revenue is dismissed.
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