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2014 (2) TMI 1229 - AT - Income TaxTransfer pricing adjustment - mam selected - CUP v/s TNMM - Held that:- As relying on earlier AY 2007-08 with regard to transfer pricing adjustment the appropriate method to be adopted was CUP in place of TNMM applied by the assessee. - Decided against assessee Addition on account of transfer pricing adjustment without granting the benefit of volume, risk adjustments and other qualitative factors - Held that:- As on account of various factors which inter-alia include an element of bad debt risk involved in the case of three parties, which is much less probable in the case of related parties, the assessee was entitled to get discount of approximately 11%. . If the same is taken into consideration, according to the facts mentioned above, no addition on this issue will survive. The impugned addition is deleted. - Decided in favour of assessee Addition on notional interest income on alleged delay in collection of invoices - Addition made on the ground that the average realization period from the AE exceeds similar period in respect of non-AE transaction - Held that:- As the assessee did not charge any interest on non-AE transactions and in some cases the realization period of non-AE transactions was more than the similar realization period of AE transactions, hence no addition was called for.- Decided in favour of assessee Disallowance under section 14A - Held that:- It has been shown that assessee has its own sufficient funds which are sufficient to cover the investment from where the assessee has earned tax free income. Moreover, on the major portion of the interest the AO has accepted the submissions of the assessee in subsequent year, therefore, we are of the opinion that addition on interest component is not called for. We confirm the addition to the extent of ₹ 90,000/- and delete the addition of ₹ 10,34,917/- - Decided in favour of assessee partly
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