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2016 (8) TMI 1510 - BOMBAY HIGH COURTTP Adjustment - Selection of MAM - Tribunal directing AO to restrict the adjustments only in relation to the transactions with the Associate Enterprise and not on the entire revenue of manufacturing segment - assessee has selected Transactional Net Margin Method and applied the same at entity level - whether if the overall margins are less than the arms length margin, the short fall must be on account of the Associate Enterprise transactions and not on pro-rata basis? - HELD THAT:- The impugned order of the Tribunal decided the issue framed herein in favour of the respondent assessee by following its decision in CIT v. Thyssen Krupp Industries India (P.) Ltd. [2015 (12) TMI 1076 - BOMBAY HIGH COURT] and in the case of CIT v. Tara Jewels Exports (P.) Ltd. [2015 (12) TMI 1130 - BOMBAY HIGH COURT]. No distinguishing features in this case to the above two cases relied upon by the impugned order has been shown to us. Question as framed does not give rise to any substantial question of law.
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