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2016 (4) TMI 86 - ITAT DELHITransfer pricing adjustment towards international transaction of ‘Job work’ - MAM - Held that:- It is discernible that the Tribunal in the immediately preceding assessment year, after treating the assessee as a job worker, has upheld the CUP as most appropriate method. Since the facts and circumstances for the instant year are admittedly similar to those of the preceding year, respectfully following the precedent, we hold that the CUP is the most appropriate method in so far as the international transaction is concerned. Reducing the amount of insurance receipt by the assessee from its AE - Held that:- Similar issue was there before the tribunal for the immediately preceding year. The Tribunal has discussed it its order by noticing that the loss, if any, would be recovered from the insurance company and paid to the AE. That is how, the tribunal deleted similar addition for the preceding year. Though ld. D.R. relied on the order passed by TPO, but could not point out any distinguishing feature in the facts of the current year vis a vis the immediately preceding year, which has been decided by the tribunal. - Decided in favour of assessee
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