Dismissing the appeal of the Revenue the Court held that the Tribunal has directed the assessee to carry out internal FAR analysis and identify proper revenue and costs vis-a-vis audited accounts to establish internal comparability under TNMM as most appropriate method (MAM). Direction of Tribunal is affirmed. Court also observed that the appellate authorities are not precluded from adopting a method different from that adopted by the assessee in the transfer pricing report. (AY. 2008-09)
PCIT v. Hellmann Worldwide Logistics India (P.) Ltd. (2024) 470 ITR 97 / 155 taxmann.com 44 (Delhi) (HC)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-
International transaction-Methods for determination of most appropriate method-Internal TNMM and not CUP method-Appellate authorities are not precluded from adopting a method different from that adopted by the assessee in the transfer pricing report-Order of Tribunal is affirmed-No substantial question of law. [S.260A]
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