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2017 (5) TMI 70 - ITAT HYDERABADTPA - ALP determination - TNMM - It was the contention of assessee that Comparable Un-controlled Price [CUP] method should be adopted for Medical Transcription Services, whereas assessee has no objection for TNMM on ITES - Held that: - similar issue was considered by the Co-ordinate Bench in earlier year i.e., AY. 2011- 12 in the case of iMedX Information Services Private Limited Versus The Income Tax Officer, Ward-2 (3) , Hyderabad and Vice-Versa [2017 (3) TMI 478 - ITAT HYDERABAD], where it was held that TPO should have adopted CUP method only for analysing the assessee’s International transactions and AO/TPO was directed to adopt CUP method for the medical transcription services and TNMM for the software development services- Since the Co-ordinate Bench has already come to a conclusion on the issue agitated by assessee, respectfully following the same, we direct the AO/TPO to re-do the exercise afresh giving due opportunity to assessee and determine the ALP accordingly, as directed in AY. 2011-12 - appeal allowed by way of remand.
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