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2012 (11) TMI 717 - AT - Income TaxTransfer pricing - ALP - selection of comparable - incremental adjustment of Rs. 5.84 crores to the income returned by the assessee as Arm's Length Price (ALP) adjustment. - held that:- transfer pricing analysis has been made by the assessee as well as the authorities below only on the basis of internal comparables. At the same time, there is no case that instances of external comparables are unavailable. External comparables are available in the industry carried on by the assessee company. In an environment where sufficient number of external comparables are available, it is imperative to examine those external comparables also alongwith internal comparables so as to come to a balanced finding on the matters relating to deciding of ALP and consequential adjustment called for, if any - matter remanded back.
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