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2010 (1) TMI 857 - AT - Income TaxDisallowance of royalty - Arms Length Price - bad debts written off cannot be factor to determine the arm's length price of any international transaction - Held that:- manner in which the A.L.P is to be determined by any of the method prescribed in Sec. 92C in provided in Rule 10B of the I.T. Rules, 1962. After examining the parameters prescribed in Rule 10B, it can be seen that bad debts written off cannot be factor to determine the arm's length price of any international transaction. In our opinion, the TPO has exceeded his limitation by following the method which is not authorised under the Act or rules – Assessing Officer directed to adopt the Arms Length Price of the royalty payable, as declared by the assessee in both the years.
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