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2012 (5) TMI 343 - AT - Income TaxTransfer pricing - Arm's Length Price (ALP) - Most Appropriate Method (MAM) - held that:- , there is no fault in the reasoning of the TPO in adopting the cost plus method (CPM) as the MAM. In this background and in view of the facts of the case we are of the considered view that the CPM is the MAM as adopted by the TPO for arriving at the value of international transactions and the ALP and interference in her action is required by the Panel. - Decided against the assessee. Restriction on deduction u/s 10B - held that:- The DRP has not dealt with each of the objections of the assessee by passing a speaking order there against and by ascribing cogent reasons for not accepting the objections of the assessee. - matter remanded for fresh decision.
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