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2018 (6) TMI 396 - AT - Income TaxTPA - MAM - CUP method - Valuation as valued by the chartered engineer, are as valued by the customs authorities, or as valued by following the DCF method - Held that:- In the circumstances, we are in agreement with the DRP that the assessee justified the price paid by them with the valuation done by the independent chartered engineers, or the customs authorities or determined under DCF method. The reasoning given by the DRP to reach the conclusion that the additions cannot be sustained is impeccable and we find it difficult to take a different view in view of the said legal position. Are of the opinion that the impugned directions given by the DRP do not suffer an illegal infirmity so as to invite the interference of this tribunal in this appeal. With this view of the matter we find the grounds of appeal are devoid of merits and the appeal is liable to be dismissed. Consequently while upholding the directions given by the DRP, we dismiss the appeal of the Revenue. Cross Objection is also dismissed.
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