Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (4) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (4) TMI 1483 - AT - Income TaxTP Adjustment - selection of MAM - TPO rejected the RPM as the most appropriate method and chose Transaction Net Margin Method (TNMM) - HELD THAT:- As identical issue considered by the Tribunal in assessee’s own case in Assessment Year 2008-0 held that TNMM is the most appropriate method in the case of the assessee for determination of ALP. We therefore dismiss ground No.2 raised by the assessee. TP adjustment restricted only to AE transactions OR non-AE transactions - HELD THAT:- TP adjustments should be done only with AE transaction. Comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected. Application of turnover filter - Companies rejected no following application of turnover filter. Determination of ALP in respect of providing guarantee by the assessee to its AE, Sabinsa Corporation, Piscutaway, New Jersey - As relying on assessee own case we direct the AO to adopt 0.5% of the guarantee amount as the ALP. We hold and direct accordingly.
|