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2014 (1) TMI 1023 - AT - Income TaxApplicability of Transfer Pricing adjustments at entity level - Held that:- Following Thyssen Krupp Industries India Pvt. Ltd. Vs. ACIT [2012 (12) TMI 71 - ITAT Mumbai] - Determination of arms length price should be restricted only to international transaction of the assessee with its AE - Decided in favour of assessee. Whether interest to be considered as operational expenses - Held that:- If the interest has been considered to be operational expenses in the case of the assessee, then the same should also be considered as operational expenses in the cases of comparables - The issue has been restored for fresh adjudication at AO level. Benefit of safe harbor of 5% - Held that:- If after computing the arms length price as per directions given above, the difference between margin taken for arms length price and margin shown by the assessee is less than 5%, then appropriate relief should be granted to the assessee.
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