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2016 (4) TMI 202 - ITAT BANGALORETransfer pricing adjustment - MAM - Held that:- To determine the ALP of the international transaction pertaining to payment of intra-group services, TNMM has to be applied following the aggregation approach as the transactions are closely linked and integral to the manufacturing operations of the assessee and therefore the determination of ALP on an aggregate basis would be more appropriate. Adjustment in connection with notional interest - Held that:- In the present case, since no income has been earned or can be said to have been earned by the assessee in respect of interest chargeable from AEs, the question of applying the provisions of section 92 of the Act does not arises. Lower authorities erred in making TP adjustment on account of notional interest on outstanding receivables from AEs and hence the assessee’s ground(s) of appeal on this issue is allowed.
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