TOYODA MICROMATIC MACHINERY INDIA PVT. LTD., NEW DELHI Vs DCIT, CIRCLE- 25(2), NEW DELHI


Quick Summary
This case involves an appeal by Toyoda Micromatic Machinery India Pvt. Ltd. against an order from the Commissioner of Income Tax (Appeals). The appeal challenges the Assessing Officer's decision to refer the matter to the Transfer Pricing Officer (TPO) without sufficient justification and disputes the TPO's determination of the arm's length price. Additionally, the appeal questions the treatment of expatriate costs in calculating the Profit Level Indicator under the Resale Price Method.

Court :
ITAT New Delhi

Brief :
This appeal is filed by the assessee against the order of The Commissioner Of Income Tax (Appeals) – 44, New Delhi [ The ld CIT A] dated 27th of December 2016 for assessment year 2011 – 12 wherein the appeal filed by the assessee against the order of The Deputy Commissioner Of Income Tax, Circle – 25 (2) New Delhi [ The Ld AO] passed u/s 143 (3) read with Section 144C of the income tax act 1961 [The Act] dated 28th of April 2015, was partly allowed.

Citation :
ITA No.3834/DEL/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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