Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2023 (10) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (10) TMI 1026 - AT - Income TaxTP Adjustment - MAM Selection - HELD THAT:- By respectfully following the above order of the Co-ordinate Bench for AY 2012-13 [2022 (12) TMI 1072 - ITAT DELHI] we hold that the RPM is the most appropriate method to determine the arms length price of International transaction undertaken be the assessee. Accordingly, we direct the AO/TPO to accept the RPM as most appropriate method and decided the issue accordingly. Inclusion of certain Companies in the final set of comparable companies - As assessee submitted that the inclusion of certain companies in the final set of comparable companies ignoring the fact that those companies fail the related party transaction filter of 25% and prayed for remanding the issue to the TPO for de-novo consideration. DR has not objected for remanding the said issues to TPO for denovo consideration. Therefore, we deem it fit to remand the issue involved to the file of the TPO for de-novo consideration on hearing the assessee. Appeal filed by the Assessee is partly allowed for statistical purposed.
|