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2018 (6) TMI 169 - AT - Income TaxTPA - comparable selection - functional dissimilarity - MAM - Held that:- The assessee is engaged in business of procuring/importing lubricants in bulk from its parent company G. S. Caltex Corporation, South Korea which holds 100% shares of the assessee company and selling in India to its customers after repacking in small packs of 910 ML to 210 ltrs, thus companies functionally dissimilar with that of assessee need to be deselected from final list - the matter need to be set aside and restored to the file of the AO/TPO for re-adjudication by re-computing ALP for benchmarking international transactions of the assessee for import of lubricating oils from its AE on merits in accordance with law in accordance with our directions as outlined in this order.
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