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2022 (6) TMI 1462 - ITAT BANGALORETP Adjustment - MAM determination - determination of ALP of an international transaction between the assessee and its Associate Enterprises (AE) u/s 92 - application of residual PSM OR TNMM - HELD THAT:- The facts in the present asst. year are identical with issue covered by the decision of coordinate bench in the assessee’s own case in [2020 (3) TMI 947 - ITAT BANGALORE] for the assessment year 2013-14 thus we set aside the question of determination of ALP to the TPO afresh applying TNMM as the most appropriate method as was done in Assessment Years 2013-14 and 2014-15 & 2015-16 in the order referred to above. Needless to say the assessee shall be given reasonable opportunity of hearing. Assessee does not make any unique contribution to the transaction, hence PSM in this case cannot be applied. Appeal of the assessee is allowed for statistical purposes.
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