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2019 (10) TMI 211 - AT - Income TaxTP Adjustment - Arm’s Length Price (ALP) in respect of an international transaction entered into between the Assessee and its Associated Enterprise (AE) under the provisions of Sec.92 - limited prayer of the Assessee in this appeal is for granting adjustment on account of capacity utilization of the Assessee and that of the comparable companies - HELD THAT:- As decided in own case [2017 (1) TMI 1687 - ITAT BANGALORE] Tribunal has given a detailed guidelines as to how to make or grant capacity utilization adjustment. Hence, we feel it proper that this matter also should go back to the file of the AO/TPO for granting capacity utilization adjustment as per the guidelines given by the Tribunal in the case of DCIT Vs Class India Pvt.Ltd. [2015 (8) TMI 1490 - ITAT DELHI] . It is ordered accordingly.
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