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2019 (6) TMI 1529 - HC - Income TaxTP Adjustment - MAM selection - correct method to be applied for determining arm's length price of the international transaction between the assessee and the associated enterprise - TPO made the adjustment to the entire segment of the manufacturing activity instead of making the adjustment for only international transaction BUT Tribunal held that the TPO was not justified in making adjustment to the entire segment of manufacturing activity without restricting the same to the manufacturing transactionHELD THAT:- Tribunal in the process relied upon and referred to the decision of the Division Bench of this Court in case of CIT v. Tara Jewels Exports (P.) Ltd [2015 (12) TMI 1130 - BOMBAY HIGH COURT]. The principles laid down in the said decision have been followed consistently in later decisions such as in cases of CIT v. Thyssen Krupp Industries India (P.) Ltd.[2015 (12) TMI 1076 - BOMBAY HIGH COURT] and CIT v. Alstom Projects India Ltd. [2016 (12) TMI 1408 - BOMBAY HIGH COURT] In the result, do not find any error in view of the Tribunal. The appeal is dismissed.
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