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2017 (6) TMI 1388 - ITAT DELHITP Addition u/s 92CA(3) - MAM selection -TNMM or CUP Method - aggregation-approach under TNMM for benchmarking international transactions relating to royalty and FTS at entity level rejected - HELD THAT:- As decided in assessee own case Hon’ble Delhi High Court at New Delhi [2017 (1) TMI 389 - DELHI HIGH COURT] the issue was remanded back to the file of the TPO and the direction was given to apply the TNMM at the entity level. The Hon’ble Jurisdictional High Court in the aforesaid order by following the judgment in the case of Magneti Marelli Powertrain India Pvt. Ltd. [2016 (11) TMI 123 - DELHI HIGH COURT] remitted the issue back to the file of the TPO for reconsideration. Thus we remand this issue back to the file of the AO/TPO to be decided as has been directed. Appeal of the assessee is allowed for statistical purposes.
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