2017 (7) TMI 1155 - HC - Income Tax

TPA - ALP determination - MAM selection - TNMM OR CUP Method - Held that - TPO, as in the previous year, accepted TNMM as the most appropriate method with regard all the international transactions of the assessee except the receipt of inter group services. The very same issue has been dealt by the Tribunal in the assessee s own cas for AYs 2007-08 and 2008-09 2015 (12) TMI 1620 - ITAT DELHI . Consistent with the view taken herein, we uphold the contention of the assessee and delete the TP adjustment. Appeals of the assessee are allowed.

Summary

The Delhi High Court dismissed the Revenue's appeal against the Income Tax Appellate Tribunal's order for the Assessment Year 2010-2011, as it had already upheld a similar order for the Assessee's case in previous years. No substantial question of law was found to arise for consideration.