Forgot password
New User/ Regiser
⇒ Register to get Live Demo
2010 (11) TMI 730 - AT - Income Tax
Addition - Arm's length price - TNMM method - Since, the average PLI calculated by the CIT(A) in para 15.1 of his order of 10.74 per cent and if we reduce 5 per cent thereof, it will come to 10.20 per cent, i.e. 10.74 - 5 per cent = 0.537 - If this is reduced from 10.74, it will come to 10.20. This will be the PLI after adjustment as per the proviso to s. 92C - This, in any case, is less than the PLI of the Takata transactions of the appellant which is 10.49 per cent - Therefore even if uphold the work done by the authorities below and adjust it by 5 per cent and then compare it with the international transactions, then again there is no need, to make any adjustment as the PLI of the tested party, i.e. the appellant, is higher than the PLI worked out by the TPO and the CIT(A) - Decided in favour of assessee.