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2015 (11) TMI 1524 - HC - Income TaxTransfer pricing adjustment - computation of income from international transactions having regard to the ALP - Held that:- Appeal is admitted on question no. (ii). Whether on the facts and in the circumstances of the case and in law, the order of the Tribunal is not perverse in view of the fact that considering the mean margin figure of 5.34% as adopted by the Tribunal, the ALP determined by the TPO is ₹ 53,68,52,698/whereas in para 12 of its order, the Tribunal states that the ALP of AE sales as computed by the TPO after applying 5.34% comes to ₹ 50,20,74,010/and assessee's sales to AE is ₹ 49,81,00,499/and there is thus disparity in the figures arrived at though the PIL value of 5.34% for both the TPO and Tribunal remain the same and that there is no basis for its conclusions based on the computation figures so derived?
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