Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2011 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2011 (2) TMI 59 - AT - Income TaxArms length price - The assessee who was mainly engaged in distribution and marketing of National Geographic Channel and the Adventure One Channel and rendering of post-production services to media companies, had international transactions with its associated enterprises i.e. M/s. NGC Asia LLC - The Learned AR on the other hand argued that the assessee had carried out due diligence in selection of comparables and the latest data available on the date of due diligence had been applied - It was found that AO compared the assessee's own payment to its associated enterprises in the immediate preceding year for the purpose of comparison on the ground that in that year the said payment was found to be at arm's length as no adjustments were made License Fees - The AO had accepted the license fees for the month of February and March 2003 to be at arm's length - The position is however different in case of transactions with a related party as in the present case, which has to be compared to unrelated party transactions to find out the arm's length price - It was held that the TNMM is the best method for computing the transfer pricing - Appeal is partly allowed
|