Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (7) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (7) TMI 734 - AT - Income TaxTPA - ALP Determination - MAM selection - rejecting RPM method - CUP method adoption - Held that:- Revenue has accepted the method in subsequent years i.e. AY 2011-12 to 2013-14. In view of the above given facts and circumstances, we are of the view that the Revenue should adopt the CUP method for benchmarking the international transaction as it is doing consistently in subsequent years. Since we have held that CUP is the most appropriate method in the case of the assessee, we not consider RPM. The AO is directed accordingly.
|