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2016 (8) TMI 1572 - AT - Income TaxTP Adjustment - whether the CUP method to be followed or TNMM to be followed to determine the ALP of assessee’s case? - HELD THAT:- As relying on Knorr Bremsc India Pvt Ltd. [2012 (11) TMI 165 - ITAT DELHI] in view of our findings on the questions of law in the assessee's appeal, it would be necessary for the authorities to consider this matter afresh in the light of those observations as well. It would be necessary upon remand for the authorities under the Act to consider whether the transactions ought to be separately benchmarked or whether the transactional net margin method ought to be adopted in respect of the same as well. In the result, the appeals of the Revenue are allowed for statistical purposes.
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