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2018 (3) TMI 1214 - HC - Income TaxDetermine the Arms Length Price (ALP) of the trading goods exported to Associated Enterprises (AE) - Tribunal was correct in law in holding that the two segments viz: manufacturing and trading are comparable - Held that:- Both the CIT(A) and the Tribunal, on facts, had found that the margins derived on export of parts to AE, are not comparable with the margins derived from sales made in the domestic market. This is primarily because the margin derived in the domestic market is on account of sales of finished goods to the extent of 97%. Besides, on facts, it was found that not only the parts and finished goods are not comparable, but the class of customers to whom they sold are also different. This resulted in difference as found on FAR analysis. The above concurrent finding of fact is not shown to be perverse in any manner. No substantial question of law.
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