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2014 (2) TMI 991 - AT - Income TaxDetermination of Arms Length Price Transfer Pricing Adjustment - Held that:- The decision in Assistant Commissioner of Income-tax Versus DHL Danzas Lemuir (P.) Ltd. [2006 (9) TMI 498 - BOMBAY HIGH COURT] followed - The assessee shared profit in the ratio of 50:50 both on the payments made by it and the receipts of freight from its AEs - The assessee paid certain sum to its AEs abroad for doing the work similar to which it did for which it received freight revenue from its AEs - the assessee has earned/paid revenue from to its AEs in the same proportion thus, the transactions have been recorded at arm's length price and there was no justification for making such addition there is no reason to interfere with the order Decided against Revenue. Denial of benefit of Percent range as per section 92C(2) of the Act Held that:- The lower authorities have erred in denying the benefit of the proviso to Sec. 92C(2) of the Act while computing the ALP thus, the benefit of the proviso to Section 92C(2) of the Act should be given to the assessee Decided in favour of Assessee.
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