Sunday 18 May 2014

TP addition ordered on basis of avg. margin of profit yielding products as no benchmark found for im

IT/ILT : Where assessee, engaged in manufacturing raw material of perfumes, declared operating loss of 2.1 per cent on export of Acsantal Crude whereas, TPO relying upon operating margin of 25.93 per cent earned by assessee's unit where Acsantal Crude was allegedly manufactured, made addition to assessee's ALP, extreme view so taken by TPO was to be rejected with a direction to benchmark transaction in question on basis of average profit margin earned on all products manufactured by assessee


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