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PR. Commissioner of Income Tax-6 Versus Mitsui & Co. India Pvt. Ltd.

2016 (5) TMI 118 - DELHI HIGH COURT

Transfer pricing adjustment - TPO, referring to Rule 10B(1)(e)(i) held that the net profit margin realized by the Assessee from an international transaction entered into with associated enterprises is to be computed in relation to the costs incurred, sales effected or assets employed by the Assessee - Held that:- ITAT has followed the decision of this Court in Li & Fung India Pvt. Ltd. v. Commissioner of Income Tax (2014 (1) TMI 501 - DELHI HIGH COURT ), where an identical issue had come up for .....

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ded against revenue - ITA 252/2016, ITA 253/2016 - Dated:- 28-4-2016 - S. Muralidhar And Vibhu Bakhru, JJ. For the Appellant : Mr. Rahul Chaudhary, Senior Standing counsel with Mr. Anup Kesari, Advocate For the Respondent : Mr. Piyush Kaushik, Advocate ORDER CM 13722/2016 in ITA 252/2016 1. Allowed, subject to just exceptions. ITA Nos. 252 and 253 of 2016 2. These appeals by the Revenue are directed against the common order dated 20th August 2015 passed by the Income Tax Appellate Tribunal ( ITA .....

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. Ltd. It acts as a facilitator for the transactions entered into by Mitsui & Co. Ltd. and other group entities. 5. The Assessee disclosed the transactions entered into during the AYs in question and a reference was made to the Transfer Pricing Officer ( TPO ) who noted that the Assessee had used the Transactional Net Margin Method ( TNMM ) as the most appropriate method for determining the Arm s Length Price ( ALP ) with the Berry ratio selected as the Profit Level Indicator ( PLI ). The TP .....

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essee from the support services was treated as income from trading and comparison was made accordingly. 6. As against the disclosed income, the TPO proposed an adjustment of ₹ 107,53,92,764/- calculating the ALP on the above basis for AY 2007-08. With the Dispute Resolution Panel ( DRP ) upholding the order of the TPO, barring exclusion of one comparable, the adjustment was increased to ₹ 110,73,05,095 for AY 2007-08. For AY 2008-09, the DRP directed the TPO to exclude three comparab .....

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