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2018 (1) TMI 752 - HC - Income TaxTPA - MAM selection - TNMM method application - concession granted to the assessee - addition u/s. 92 on the basis of order of TPO, who had calculated Transfer pricing on the basis of existing data available on record - Held that:- After examining the matter, we find that the entire matter has been considered at length and the department does not deny that TNMM method was being used for exporters and, therefore, the resultant concession granted to the assessee on this count is correct. It has also been noticed by the Tribunal that even otherwise the difference in the PLI was only marginal and was below 5%. The question of law is, therefore, answered in favour of the assessee and against the department.
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