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2013 (11) TMI 141 - ITAT MUMBAIArms length price for transportation services provided to associated enterprise The assessing officer referred the case to Transfer Pricing Officer - Held that:- Only the co-loading segment of the company is engaged in comparable activity, i.e., courier services Margins of the comparable company and the assessee were erroneously computed Based on the remand report of the transfer pricing officer the revised arms length margin was computed to -3.06 percent and the arithmetic mean operating margin of the comparables at 1.18 per cent based on the data of the comparable companies In price terms the (-) 5 per cent. figure comes to Rs. 12,31,972,759 while the (+) 5 percent comes to Rs. 13,61,654,102 whereas the appellant's price is Rs.13,52,402,382 which falls within the permitted range of 5 percent. Deduction u/s 43B Held that:- The entire amount was paid before the closure of the financial year or within the due date for filing the return of Income Decided against Revenue.
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