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2012 (11) TMI 554 - AT - Income TaxTransfer pricing adjustment and levy of interest under section 234B – Whether transfer pricing adjustment should be computed with respect to gross turnover of the assessee or should be limited to volume of transaction entered into with the associate enterprises – Held that:- Claim of the assessee is very reasonable as the adjustment has to be made only with respect to transactions with associate enterprises based on arms-length price and not with respect to total purchases/sales. This view is supported by several decisions of the Tribunal - issue restored to the file of AO/TPO for fresh computation of transfer pricing adjustment after necessary examination and after allowing opportunity of hearing to the assessee - In the result, appeal of the assessee is allowed for statistical purposes.
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