Provisions of Arms Length Price u/s 92 of the Income Tax Act

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Last updated: 10 July 2021
Quick Summary
This case involves M/s. ASM Technologies Ltd. appealing a final assessment order for the 2012-13 assessment year. The company, which provides software development, manpower supply, and training, engaged in international transactions with a foreign associated enterprise (AE). The core issue was determining the Arms Length Price (ALP) for these transactions, with the Transfer Pricing Officer (TPO) adopting the Transaction Net Margin Method (TNMM) as the most appropriate method, contrary to the assessee's preference for the Comparable Uncontrolled Price Method (CUP).

Court :
ITAT Bangalore

Brief :
This is an appeal by the assessee against the final order of assessment dated 18.11.2016 of the DCIT, Circle –1(1)(2), Bengaluru, passed under section 143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 (hereinafter called ‘the Act’), for Assessment Year 2012-13.

Citation :
IT(TP)A No.66/Bang/2017

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1 Year PLAN
1999
(Excl. of GST ₹359)

2 Years PLAN
3499
(Excl. of GST ₹629)

BEST VALUE
3 Years PLAN
4999
(Excl. of GST ₹899)

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