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2017 (11) TMI 1471 - AT - Income TaxMargin calculation - inclusion of payment of arbitral award on behalf of the AE - rule of consistency - Held that:- Payment on account of arbitration award cannot form part of the cost base for purpose of margin calculation. Ld. TPO is to examine the issue on factual basis by following the rule of consistency in the light of its order passed in AY 2012-13. So, grounds no.3 & 12 are determined in favour of the taxpayer for statistical purposes. Risk adjustment claim - Held that:- The taxpayer in this case is entitled for risk adjustment to the net margin of comparables for bringing them at par with the taxpayer - Decided in favour of assessee.
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