Wednesday, 8 April 2015

No TP adjustment by ignoring transaction in entirety and by picking up those which are in revenue's

IT/ILT : Where TPO made addition to assessee's ALP in respect of purchase of raw material from AE located abroad by applying internal CUP method, matter was to be remanded back for disposal afresh with a direction that transaction of import from AEs was to be considered in entirety to calculate amount of adjustment instead of only those common products whereby import price from AEs was higher vis-a-vis purchase price from local third parties


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