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2012 (11) TMI 174 - AT - Income TaxComputation of arm's length price – ALP - working capital adjustment – selection of comparable - Held that:- Price charged by the assessee varies by more than 5% from the Arm's Length Price - adjustment is to be made to the income of the assessee, being the difference between the arm's length price and the price charged by the assessee from it's A.Es for export services - assessee has given the relevant details but these details have neither been looked into by the learned TPO nor by the Dispute Resolution Panel - TPO has not asked any further details after this letter otherwise assessee could have submitted any other details if required – matter remitted it to the Assessing Officer for a limited purpose i.e. learned Assessing Officer shall investigate the issue about granting working capital adjustment to the assessee - appeal of the assessee is partly allowed.
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