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2023 (11) TMI 788 - ITAT BANGALORETP Adjustment - selection of tested party - CIT(A) did not allow the plea of foreign AE to be the tested party for the purposes of computing the arms length margin - HELD THAT:- It is a settled principle in the transfer pricing provisions that the tested party should be the party in respect of which reliable data for comparison is easily and readily available. This view has been considered by Hon’ble Delhi Tribunal in case of Ranbaxy Laboratories Ltd. vs. ACIT [2008 (1) TMI 445 - ITAT DELHI-H]. As relying on assessee own case for A.Ys. 2010-11 to 2011-12 [2021 (3) TMI 146 - ITAT BANGALORE] we direct the Ld.AO/TPO to consider foreign AE as the tested party.
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