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2015 (3) TMI 1271 - AT - Income TaxDepreciation om technical knowhow - Held that:- Claim of deprecation becomes eligible as it is an intangible asset on which assessee has claimed depreciation on WDV. Deemed international transactions - ALP determination - nature of transaction - Held that:- Since the transactions between Matrix and Astrix both being resident companies in India do not fall within the definition of international transactions so as to necessitate the computation of arms length price under the T.P. provisions of the Act, DRP accepted the assessee’s objections. DRP also noted that the transactions between the Matrix and assessee does not in any way shift any profits out of India, since both the entities are taxable entities in India and the question of applying the T.P. provisions does not arise. Since the TPO does not have any jurisdiction to examine the domestic transactions in the impugned assessment year, the DRP has rightly held that stand of the TPO fails. Domestic transactions cannot be examined under T.P. provisions for the impugned assessment year - Decided against revenue
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