Rule 10 B (1)(e)(i) does not suggest that the ‘costs’ would mean the FOB value of goods in transfer pricing calculation
Court :
INCOME TAX APPELLATE TRIBUNAL
Brief :
That the learned Additional Director of Income Tax, Transfer Pricing Officer-II(2), New Delhi (Ld. TPO)/ Ld. AO have erred both in law and on facts in making an addition of Rs.3,97,10,488/- on account of alleged understatement of arm’s length price in respect of commission income earned by the Appellant from its Associated Enterprises (“herein after referred to as AEs”).
Citation :
Sojitz India (P) Ltd., 7th Floor, EROS Corporate Towers, Nehru Place, New Delhi. PAN-AAICS8883N (APPELLANT) Vs DCIT, Circle-9(1), C.R. Building,New Delhi (RESPONDENT)
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