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2016 (3) TMI 1393 - DELHI HIGH COURTTP Adjustment - whether the ITAT was correct in accepting the Assessee’s contention regarding the application of the resale price method (‘RPM’) for determining the arm’s length price (‘ALP’) of the international transaction entered into by the Assessee with its associated enterprise (‘AE’)? - HELD THAT:- The Court finds that the ITAT has, in the impugned order, held that even if the ALP is determined by applying the Transactional Net Margin Method (‘TNMM’), the gross profit margin earned by the Assessee in respect of export of motorcycles to its AE is 15.83% as compared to 10.75% in respect of export of motorcycles to unrelated parties. It was also seen that the export price realised per motor bike in the case of Assessee was much better when compared to that realised by other companies in the same line of business. These findings of fact have not been specifically assailed by the Revenue. Consequently, the Court declines to frame a question on this issue. Appeal dismissed.
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