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2014 (6) TMI 697 - AT - Income TaxTransfer pricing adjustment – Determination of ALP - Adoption of most appropriate method – Held that:- Following Twilight Jewellery (P.) Ltd. Versus Dy. Commissioner of Income Tax [2014 (4) TMI 200 - ITAT MUMBAI] - if any of the direct methods like CUP, RPM or CPM can be adopted for bench marking the transactions, then they should be given preference and once these traditional methods are rendered inapplicable then only the TNMM should be resorted to as a last measure - this argument of applicability of internal CUP has not been taken up either before the TPO or before the DRP – thus, the matter is required to be remitted back to the TPO for fresh adjudication – Decided in favour of Assessee.
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