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2018 (10) TMI 1981 - AT - Income TaxTP Adjustment - adoption of appropriate method for determining the ALP of international transactions - assessee had adopted CPM method as the most appropriate method for determination of PLI by GP/OC - HELD THAT:- We observe that the business model of the assessee is same as in the preceding and succeeding years. The facts are unchanged. It is clear from the Paper book submitted by the assessee that for the assessment year 2010- 11 and 2013-14, the cost plus method has been accepted by the Revenue in the same facts of the case of the assessee. This has not been controverted by the ld. DR. We, therefore, find that rule of consistency should have been adopted by the authorities below as held in the case of Racold Thermo Ltd. [2015 (10) TMI 1747 - ITAT PUNE] The decision rendered in Fritidsresor Tours and Travels India P. Ltd [2015 (11) TMI 1884 - ITAT DELHI] is also applicable to the present case, as in that case, the assessee was engaged in the same line of business and CPM has been accepted by the Co-ordinate Bench of Tribunal, as most appropriate method, as reproduced above. Respectfully following the above decisions, we allow the appeal of the assessee.
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