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2021 (6) TMI 92 - AT - Income TaxAdmission of additional ground - TP Adjustment - inappropriate use of Transactional Net Margin Method (“TNMM”) instead of the Resale Price Method (“RPM”) as the most appropriate method (“MAM”) for benchmarking the Appellant’s international transaction of import of dental products from its foreign AE i. e. Dentsply International, USA (“ international transaction”) - HELD THAT:- Keeping in view, the judgment of the Hon’ble Apex Court in the case of National Thermal Power Co. Ltd. [1996 (12) TMI 7 - SUPREME COURT], the additional ground filed by the assessee is accepted. Selection of MAM - As relying on Mattel Toys (I) (P.) Ltd. Vs DCIT [2013 (10) TMI 555 - ITAT MUMBAI] we hereby direct to revenue to determine Arm’s Length Price (ALP) considering Resale Price Method (RPM) as Most Appropriate Method (MAM).
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