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2015 (10) TMI 1067 - ITAT PUNETransfer pricing adjustment - Held that:- In the subsequent assessment years of 2006-07 and 2007-08, the nature of functions of the assessee in the segment of Provision of marketing support services to the associated enterprises has been accepted by the TPO to be that of a service provider and not a distributor. Even with regard to the manner of computing the PLI in the subsequent assessment years the formula adopted by the assessee of Operating Profits/ Total cost has been accepted. For all the above reasons, the present appeal of the Revenue is devoid of any merit. - Decided against revenue.
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