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2015 (6) TMI 213 - AT - Income TaxTransfer pricing adjustment - commission percentage, on the basis of FOB value of the goods, from the transactions with non-AE, are at arm’s length under the “indenting business” segment - Held that:- In the instant case, the commission earned from non AE transaction is an appropriate a suitable internal comparable for the purpose of comparing the international transactions affected by the assessee with Associate Enterprise pertaining to similar segment during the financial period under consideration. In view of above, respectfully following the view taken by the Tribunal for AY 2008-09 we inclined to hold that the issue is squarely covered in favour of the assessee and the impugned addition made by the AO in pursuant to direction of the DRP by passing the impugned order u/s 142(3) r.w.s. 144C of the Act is not sustainable and the AO/DRP is directed to delete the same. Decided in favour of assessee.
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