Friday, 3 October 2014

ITAT directs AO to determine ALP on basis of internal comparables considering its earlier order

IT/ILT: Where assessee was engaged in transactions of rendering software development services to its AE located abroad, in view of order passed by co-ordinate bench of Tribunal in assessee's own case relating to earlier assessment year, matter relating to determination of ALP of aforesaid transactions was to be remanded back for disposal afresh on basis of internal comparison of profits from international transactions entered into with AE and with unrelated parties


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