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2023 (4) TMI 456 - ITAT CHENNAITP adjustment in relation to import of fixed assets - TPO determined ALP of the old machineries at NIL - assessee has purchased various fixed asset from different AEs - HELD THAT:- TPO has asked the assessee to produce invoices/bills, date of purchase by AE and utilization of the machineries, etc. and the assessee has not filed any details before the TPO. No details were brought on record either before the ld. DRP or even before the Tribunal. Therefore,we are of the considered opinion that the TPO has rightly came to a conclusion that the ALP of the old machineries at NIL, which was confirmed by the ld. DRP. We find no infirmity in the order passed by the ld. DRP/Assessing Officer. Accordingly, the ground raised by the assessee is dismissed.
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