Section 92C(1) provides that ALP of international transaction and SDT shall be determined by adopting “MAM”. Sub-section (2) provides that most appropriate method shall be applied, for determination of ALP, in the manner prescribed. Rule 10B lays down the methodology for computation of ALP for each of the method. The selection of one method as […]
KODAK INDIA PVT LTD v ACIT (2013) 155 TTJ 697 (Mum ITAT)
The Tribunal rejected the action of the TPO of computing ALP by allocating the consideration received on sale of business on the basis of revenue ratio on the ground that it is not prescribed method and no seventh method could be adopted by the TPO. Facts The taxpayer sold its medical – imaging business to […]
CIT v CA COMPUTER ASSOCIATES INDIA PVT LTD (2013) 351 ITR 69 (Bom)
It was held that the ALP should be determined as per the procedure prescribed. Any deviation from the prescribed procedure cannot be sustained. Facts The taxpayer was engaged in the business of licensing mainframe, midrange and system infrastructure software products of CA Management Inc. of the USA. The taxpayer had set-up a Technical Support Centre […]