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2018 (5) TMI 262 - HC - Income TaxCompute the TP Adjustment proportionate to AE turnover - assessee has applied TNMM at entity level - prorata adjustment when TNMM is applied at entity level - Held that:- Transfer Pricing Adjustment is not to be done at the entity level but only in respect of international transactions of the Respondent with its Associated Enterprise (AE). This, on the application of proportionate method. See CIT v/s. M/s. Ratilal Becharlal & Sons [2015 (11) TMI 1524 - BOMBAY HIGH COURT] Comparability selection criteria - Held that:- Companies functionally dissimilar with that of assessee to be deslected. If the extra ordinary loss incurred in the subject Assessment Year as excluded while arriving at the profit of the Respondent-Assessee, then even in the absence of M/s. Rajasthan Udyog & Tools Ltd., and M/s. Hitco Tools Ltd., being considered to be a comparable, the profit margin of the Respondent-Assessee, would fall within +/5% of the profit margin of the comparables as permitted under Section 92C of the Act
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