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2015 (8) TMI 6 - AT - Income TaxTP adjustments - selection of tested party in determination of Arm’s Length Price (ALP) - Held that:- Profitability of the selected Comparable companies in domestic market may vary with the profit margins available abroad, particularly in the USA market. DRP also rejected the method solely on the reason that AE was not selected as tested party. Therefore, keeping in mind the submissions made by the Ld. Counsel, the issue of selection of method of resale price method or of TNMM or any other method suitable to the international transactions is also restored to the file of A.O. to examine the suitability of various methods and consider accordingly Thus restore the issue of selection of most appropriate method as well as selection of the tested party to the file of AO/TPO to examine afresh, whether AE can be selected as tested party and RPM can be selected as most appropriate method. - Decided in favour of assessee for statistical purposes.
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