Wednesday, 13 May 2015

TPO couldn't change TP method in subsequent year if circumstances remained unchanged

IT/ILT: Where TPO made addition to assessee's ALP in respect of export of tractors to AEs by adopting CUP method, in view of fact that in earlier assessment years TPO had been accepting TNMM as most appropriate method for similar transactions, by applying rule of consistency, impugned addition deserved to be deleted

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