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2020 (2) TMI 1715 - ITAT PUNETP Adjustment - AO/DRP rejecting internal Transactional Net Margin Method (TNMM) and applying the external TNMM - HELD THAT:- Pune Benches in assessee’s own case reported in A.Y. 2007-08 [2015 (5) TMI 644 - ITAT PUNE] held that the internal THMM is the most appropriate method to compute arm’s length price for the international transactions of purchase of raw material and components from associated enterprises AR brought to our notice the ITAT, Pune Benches upheld the same internal TNMM for A.Ys. 2008-09, 2010-11 and 2011-12. There is no contrary order brought on record by the respondent-revenue in this regard. Therefore, we uphold the internal TNMM adopted by the assessee in determining ALP of its international transactions in purchase of raw material, components and finished goods. Accordingly, ground No. 2 raised by the assessee is allowed. Upward TP adjustment - international transaction in respect of payment made to AEs for corporate support services - HELD THAT:- As in assessee’s own case for A.Y. 2010-11 [2019 (11) TMI 1190 - ITAT PUNE] dealt the issue and decide the same in favour of assessee
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