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2014 (1) TMI 891 - ITAT MUMBAIError in determination of ALP – Net profit margin on the entire turnover applied – Held that:- The decision in Phoenix Mecano (India) Ltd V/s DCIT [2011 (12) TMI 178 - ITAT MUMBAI] followed - the final adjustment on account of transfer pricing has to be made only in respect of transactions with Associated Enterprises and not in respect of entire turnover of the assessee as made by the revenue authorities - the adjustment made to determine the ALP by considering the entire purchases of the assessee in the assessment years under consideration is not in accordance with law - the orders of the authorities below set aside and the matter restored to the AO with a direction that the adjustment, if any, is required to be made due to determine of ALP, it should be restricted only to the purchases made from Associated Enterprises and not to the entire turnover of the assessee-company – Decided in favour of Assessee.
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