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Pr. Commissioner of Income Tax-1 Versus Avery Dennison (India) Pvt. Ltd.

2016 (9) TMI 244 - DELHI HIGH COURT

Transfer pricing adjustment - determination of the Arms Length Price (‘ALP’) - Assessee adopted the Transactional Net Margin Method (‘TNMM’) and had taken Operating Profit/Total Cost as the profit level indicator (‘PLI’) - TPO, however, applied the C .....

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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 taken by the ITAT is plausible one and does not warrant any interfe .....

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/2016, ITA 392/2016, ITA 401/2016, & ITA 402/2016 - Dated:- 28-7-2016 - S. MURALIDHAR & JUSTICE NAJMI WAZIRI JJ. Appellant Through: Mr. P. Roy Chaudhuri, Senior Standing Counsel. O R D E R 1. The challenge in these appeals by the Revenue is to an .....

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e 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 Met .....

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