2013 (3) TMI 610 - HC - Income Tax

Computation of Transfer pricing adjustment - Tribunal accepting the Cost Plus Method adopted by the assessee to arrive at Arm s Length Price determined by the Transfer Pricing Officer - Held that - Tribunal accepted the the Cost Plus Method to arrive at Arm s Length price in respect of its international transaction relating to purchase of raw materials. The Tribunal also records the fact that Assessing officer has accepted the Cost Plus Method adopted by the respondent assessee in arriving at Arm s Length Price for subsequent assessment years 2003-04 and 2004-05. The appellant revenue does not urge that the facts in the subsequent years are materially different from the facts existing in the present assessment year - No substantial question of law - Decided against revenue.

Summary

The High Court Bombay dismissed the revenue's appeal for assessment year 2002-03 regarding the Cost Plus Method used by the assessee to determine Arm's Length Price. The Tribunal's decision was upheld based on consistency with subsequent assessment years. No costs were awarded.