2016 (9) TMI 244

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..... e adjustment on the basis of which the AO framed the assessment on 1st February 2011 - whether it was not within the purview of the TPO to determine if some of the services resulted in any actual benefit to the Assessee or not? Held that:- Having heard learned counsel for the Revenue at length and having perused the orders of the TPO, CIT(A) and the ITAT, the Court is of the view that the view .....

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..... 2. The question urged by the Revenue concerns the determination of the Arms Length Price ( ALP ) by the Transfer Pricing Officer ( TPO ) of the international transactions involving the Assessee and its Associated Enterprise ( AE ). The Assessee adopted the Transactional Net Margin Method ( TNMM ) and had taken Operating Profit/Total Cost as the profit level indicator ( PLI ). The TPO, however, app .....

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