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2015 (2) TMI 354 - AT - Income TaxTransfer pricing adjustment - CIT(A) reducing the cost of goods received free of cost of ₹ 9.1O crore, from the total cost of goods of ₹ 14.76 crore and applying 6% mark up on such reduced amount of ₹ 5.66 crore, thereby allowing the assessee relief of ₹ 54,60,000/- - Held that:- Ld. CIT(A) did not commit any error in determining the arm’s length price. The impugned transaction is in accordance with the view point taken in respect of A.Y 2007-08 as it is in accordance with the principle of consistency, which is applicable to the Income-tax cases as per decision of Hon’ble Bombay High Court in the case of CIT vs. Gopal Purohit [2010 (1) TMI 7 - BOMBAY HIGH COURT] wherein their Lordships have held that there ought to be uniformity in treatment and consistency when the facts and circumstances are identical, particularly in the case of the assessee. In this case also, what Ld. CIT(A) has done is that he has brought uniformity in the treatment and consistency to bring the TP adjustment at par with the treatment adopted by the Department in respect of assessment year 2007-08. - Decided against revenue.
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