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2019 (6) TMI 238 - AT - Income TaxTP Adjustment - arm’s length price of international transaction by applying CUP as MAM - HELD THAT:- Respectfully following assessee own case in [2018 (5) TMI 848 - ITAT DELHI] , we also set aside this issue back to TPO/AO for fresh determination of the arm’s length price of international transaction by applying CUP as most appropriate method. It is also directed that in case TPO finds that identical/similar comparables are not available under CUP, then he is free to apply any other appropriate method for determination of arm’s length price of international transaction of management group cost. Addition on account of imputing interest on outstanding receivables - HELD THAT:- It is observed that this Tribunal for assessment year 2011-12 has directed AO to adjudicate afresh considering agreed credit period allowable to Associated Enterprise by assessee. Respectfully following same, we direct AO to adjudicate this issue afresh on basis of documents/evidences filed by assessee. Assessee is directed to file agreement under which payment has to be received from AE against services provided by assessee. Upon analysis of such agreement, assessee shall submit evidences in respect of agreed allowable credit period for making payments by AE to assessee based upon which interest shall be computed.
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