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2023 (3) TMI 459 - AT - Income TaxTP Adjustment - Comparable selection - DR submitted that the multiple of 10 times of the turnover should be adopted while adopting the turnover filter - HELD THAT:- We hold that the DRP was justified in its directions to include only those companies having turnover of Rs.200 crore to Rs.2000 crore as a comparable for making the TP study in the assessee’s case. It is ordered accordingly. Our order will have impact only on non-US AE’s transactions, since the international transaction of the assessee with its US based AE had already been settled under the MAP Resolution. It is ordered accordingly.
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