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2015 (12) TMI 1513 - HC - Income TaxTransfer pricing adjustment - ALP adjustment - appropriateness of adopting CUP method as against the TNMM for determination of the ALP - Held that:- As the present appeals are concerned, the Court finds the impugned order of the ITAT to be well reasoned and researched to hold that the assessee’s contention to the effect that the arm’s length price of services rendered to, or received from, the associated enterprises, which was computed on the basis of the same 50:50 model as is the industry norm and as has been employed by the assessee for computing similar services to the independent enterprises, was at arm’s length. Accordingly, the impugned arm’s length price adjustment stands deleted. The legal principles governing the determination of ALP in a TP adjustment exercise have been expounded lucidly by the ITAT in the impugned orders. - Decided against revenue
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