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2022 (1) TMI 1147 - AT - Income TaxTP Adjustment - selection of MAM - granting an internal margin of 23% worked out by the appellant under the Transactional Net Margin Method - CIT(Appeals) directing the AO to apply the internal Transactional Net Margin Method (TNMM) as the most appropriate method (MAM) for benchmarking the international transactions entered into by the assessee with its Associated Enterprise (AE) - HELD THAT:- As identical issue of applying internal TNMM had come up for consideration before the ITAT Bangalore Bench in assessee’s own case for the AY 2010-11 [2015 (11) TMI 1545 - ITAT BANGALORE] we uphold the orders of the CIT(Appeals) applying internal TNMM method for determination of the ALP. We may also observe that the manner of determination of internal margin under the internal TNMM has not been questioned. In these circumstances, we dismiss the relevant grounds of appeal of the revenue.
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