Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2011 (3) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2011 (3) TMI 565 - AT - Income TaxArms Length Price - The argument of the assessee that the services rendered by the assessee are only basic services to its holding company and therefore the prices declared by the assessee are to be treated as reasonable - Held that: - the price declared by the assessee for its international transactions cannot be accepted as Arms Length Price for the reason that the assessee has not placed before us any cost model and market potential of the products so as to accept or reject the bench mark profit of 10 per cent. - Transfer Pricing Officer has worked out the operating profit at 20.68 per cent of the operating cost. We feel that a nominal modification is called for in this rate of operating profit, accepting certain valid contentions of the learned representative regarding the competence level of its employees; the remuneration payable to them and the effect of the safe environment in which the assessee was functioning.
|