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2016 (1) TMI 1366 - AT - Income TaxTPA - most appropriate method for determining ALP & quantification of TP adjustment - Held that:- The issue in the present case is covered by the decision of Tribunal in assessee’s favour by the Tribunal’s order in assessee’s own case for A.Ys. 2003-04 & 2004-05 [2011 (2) TMI 1283 - ITAT AHMEDABAD] wherein Hon’ble ITAT has held that TNMM method is the most appropriate method. Thus the entire TP adjustment should have been deleted. Claim of bad debts written off - Held that:- The amount which has been claimed by the assessee as bad debts have been written off in the books of account. Hon’ble Apex Court in case of TRF Ltd. vs. CIT (2010 (2) TMI 211 - SUPREME COURT ) has held that in view of the amended provisions w.e.f. 01.04.1989 it is not necessary for the assessee to establish that the debt, in fact has become irrecoverable and it is enough if the bad debt is written off as irrecoverable in the account of the assessee. - Decided in favour of assessee
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