Thursday, 19 September 2013

No TP adjustment to be made if price declared by assessee is within tolerable limit

IT/ILT: Where Commissioner (Appeals) determined arm's length price by considering entity level results of assessee which included all international transactions, in such a case, when over all price of assessee was within tolerance limit of 5 per cent, in terms of proviso to section 92C(2), no adjustment to ALP determined by assessee was permissible


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