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2014 (4) TMI 563 - HC - Income TaxDeletion made u/s 92CA(3) of the Act Determination of ALP Authenticity of the rate list Held that:- The determination of Arms Length Price u/s 92C of the Act is to be done as per the Rules contained in Rule 10B Clause A to subsection 10 - In terms of clause (c) of subsection (3) of Rule 10D of the Rules, the price publications as long as it was authentic and reliable, would be relevant materials - mere base of the organisation would be of no consequence - though the price quotations of the MPOB would be entitled to its due and full weightage and respect, would not necessarily mean that the other quotations would lose their significance, unless, it is pointed out that such quotations lack basis - the only objections with the TPO was to take into consideration the rate quotations of the Oil World were, that were not based in Malaysia and that it was an independent organisation, which had nothing to do with the old price prevailing in Malaysia - When the CIT (A) as well as the Tribunal have accepted the reliability and authenticity of the organisation and its publication of rate list, such objection of the TPO must be overruled thus, there was no substantial question of law arises for consideration Decided against Revenue.
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