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2015 (12) TMI 1779 - AT - Income TaxTPA - whether the internal comparables should be adopted over external comparables for the purposes of computing ALP, in respect of transaction pertaining to export of goods - TNMM has been accepted by both the parties as MAM - Held that:- Internal comparables are to be preferred to external comparables. There is no dispute that the assessee has internal comparables. Geographical differences are not relevant when FOB price is considered. Set aside the matter to the TPO with a direction to consider the sale in respect of export to AE’s at FOB value. Even otherwise, except for export to Germany, there are no geographical variations. The ld.TPO is directed to apply internal comparables, at FOB value, as in his view, this value is the comparable value. The assessee is directed to furnish the audited financials of the segmental accounts - Restore the issue to the files of the TPO/AO, for fresh adjudication of the ALP, as per the directions given herein - Decided in favour of assessee for statistical purposes.
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