Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2010 (10) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2010 (10) TMI 740 - AT - Income TaxAddition 92CA(3) - International transaction with associated enterprise - Deduction u/s 80HHC - Arms length price - TNMM method or cost plus method - TNMM requires comparison of net profit margins realised by an enterprise from an international transaction or an aggregate of a class of international transactions and not comparisons of operating margins of enterprises - assessee has not taken the ground that cost plus method is the most appropriate method and the TPO has struck down this method as inappropriate - Decided in favour of the assessee by way remand to AO Regarding computation of relief under section 80HHC - Assessing Officer was directed to exclude the disputed amount of foreign exchange fluctuation difference from the income of the current year and include it in the income of the immediately preceding year in which the exports were made by the assessee and allow the deduction accordingly - appeal of the revenue is allowed for statistical purposes
|