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2021 (8) TMI 953 - AT - Income TaxTP Adjustment - benchmarking of AMP services - HELD THAT:- Applying the principles laid down by the Hon'ble High Court in the assessee's own case [2016 (10) TMI 1073 - DELHI HIGH COURT] the benchmarking is undertaken by comparing the gross profit earned by the assessee net of AMP expense with similar adjusted gross profit margin earned in undertaking uncontrolled transactions. Since, the adjusted gross profit margin earned by the assessee from international transaction at 14.92% is higher than the adjusted gross profit margin earned on similar transactions with unrelated third party at 8.17%, the entire adjustment made by the TPO is liable to be deleted. - Decided in favour of assessee.
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