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2014 (9) TMI 1001 - AT - Income TaxTransfer pricing adjustment - selection of comparables - Held that:- RPT filter should be considered at 15% of the total revenue and companies having RPT in excess of 15% of total revenues are to be excluded from the list of comparables. In this view of the matter, the order of the learned CIT (Appeals) holding that companies are not to be considered as comparables even if they have a single RPT i.e. ;that the RPT is in excess of 0%, is reversed. Entitlement to standard deduction of 5% from the ALP under the proviso to section 92C(2) - Held that:- In view of the amendment brought about by the Finance Act, 2012 by introduction of the clarificatory amendment of section 92CA(2) of the Act w.r.e.f. 1.4.2002, the issue has been settled and therefore the assessee is not entitled to the benefit of 5% standard deduction from the ALP of international transactions.
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