“most appropriate method”

Transfer PricingSection 92CSection 92C1,345 judgments

The decision most relied on for most appropriate method is CIT v. Cushman & Wakefield (India) (P.) Ltd. (367 ITR 730), cited in 120 judgments on BharatTax.

Leading authorities on most appropriate method

CIT v. Cushman & Wakefield (India) (P.) Ltd.

367 ITR 730 · 2014 · High Court

120

citing judgments

This case determines the Arm's Length Price (ALP) for intra-group services and reimbursements, clarifying when charges constitute services warranting a mark-up versus mere pass-through costs. It provides guidance on the circumstances under which an ALP adjustment, including an ALP of 'nil', is appropriate for such transactions.

Dresser-Rand India (P.) Ltd. v. Addl. CIT

13 Taxmann.com 82 · 2011 · High Court

citing judgments

An Assessing Officer cannot disregard an assessee's decision to avail services from associated enterprises, even if the assessee has internal expertise, as the determination of necessity is the assessee's prerogative. The Transfer Pricing Officer's role is to determine the arm's length price, not the need for the service itself.

CIT v. EHPT India P Ltd.

350 ITR 41 · 2013 · High Court

citing judgments

The headcount method is an appropriate allocation key for indirect expenses between eligible and non-eligible units when it has been consistently accepted by revenue authorities and there is no just cause for abandoning it. Deviation from a consistently followed and accepted method can disturb or distort profits.

Mobis India Ltd. v. Dy. CIT

38 Taxmann.com 231 · 2013 · ITAT

citing judgments

A working capital adjustment is unreliable if it is based on broad approximations, estimations, and assumptions, and the assessee fails to demonstrate how the adjustment was arrived at.

LG Electronics India Pvt. Ltd. v. ACIT

29 Taxmann.com 300 · 2013 · High Court

citing judgments

The 'bright line test' is not an appropriate method for determining the existence of an international transaction for calculating arm's length price. This ruling overrules prior special bench decisions on AMP expenses.

Magneti Marelli Powertrain India Pvt. Ltd. v. DCIT

389 ITR 469 · 2016 · High Court

citing judgments

The Assessing Officer (AO) or Transfer Pricing Officer (TPO) cannot dispute the application of the TNMM method if they have already accepted it as the most appropriate method for certain international transactions, especially when other transactions are intrinsically linked.

Skoda Auto India (P) Ltd. v. ACIT, Aurangabad

30 SOT 319 · 2009 · ITAT

citing judgments

The Tribunal may allow adjustments for differences between the tested party and comparable companies to eliminate material differences, provided accurate and credible evidence is furnished.

Principal Commissioner of Income-tax-6 v. Matrix Cellular International Services (P.) Ltd.

90 Taxmann.com 54 · 2018 · High Court

citing judgments

The Resale Price Method (RPM) is the most appropriate method for determining the arm's length price of a distributor who does not add significant value to the goods purchased.

Judgments citing most appropriate method

Omni Active Health Technologies Ltd., Mumbai vs. Addl/Jt./Dy/CIT/Asstt/ITO, National E-Assessmetnt Centre, Delhi

In the result, appeal of assessee is partly allowed

ITA 1224/MUM/2021[2016-17]Status: DisposedITAT Mumbai17 Oct 2022AY 2016-17

Bench: Shri Baskaran Br & Sh. Anikesh Banerjee

Section 143(3)Section 144C(13)Section 144C(5)Section 35Section 69CSection 92C(1)

length. 1:2 The learned AO/TPO/DRP erred in rejecting Transactional Net Margin Method ("TNMM") which was determined by the Appellant as the most appropriate method as per provisions of section 92C(1) of the Act. 1: 3 The Appellant submits that considering the facts and circumstances of its case ... length price in relation to an international transaction is to be determined by one of the prescribed methods which is most appropriate method having regard to the nature of transaction, class of transaction, class of associated persons, functions to form by such person, or such other relevant factors. Section

Frost & Sullivan (I) P. Ltd, Mumbai vs. DCIT 8(1), Mumbai

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 7899/MUM/2010[2006-07]Status: DisposedITAT Mumbai17 Oct 2022AY 2006-07

Bench: Shri Prashant Maharishi, Am & Shri Rahul Chaudhary, Jm Dy. Commissioner Of Income Frost & Sullivan (I) P. Ltd. Tax, Tower Vi, Iv Floor, Solitaire Central Circle 8(1), Corporate Park, Chakala, Vs. Andheri (E) Aaykar Bhavan Mumbai-400 093 Mumbai-400 020 (Appellant) (Respondent) Pan No. Aaacf4252A Assessee By : Shri Madhur Agrawal, Ar Revenue By : Shri Sumit Kumar, Sr. Ar Date Of Hearing: 20.07.2022 Date Of Pronouncement : 17/10/2022

For Appellant: Shri Madhur Agrawal, ARFor Respondent: Shri Sumit Kumar, Sr. AR

Section 133(6)Section 143(3)Section 144C(13)Section 144C(5)Section 92C(2)Section 92C(3)

provided by the CP division has been rejected on totally untenable grounds and the Transactional Net Margin Method (TNMM'), which is not the most appropriate method under the circumstances, has been adopted. (d) the appellant's comparison has been made with entities having totally different functional and risks profile ... receipt of market analysis services of ₹52,79,958/-. The assessee company has adopted Transactional Net Margin Method as the most appropriate method. It selected ten comparables and worked margin on the cost of these services at 11.74%. The learned Transfer Pricing Officer rejected all the ten comparables

Merck Specialities Pvt. Ltd, Mumbai vs. The Dy. Commissioner of Income Tax, Circle-7(2)(1), Mumbai

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 2056/MUM/2016[2011-12]Status: DisposedITAT Mumbai14 Oct 2022AY 2011-12

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Ms. Aarti Vissanji a/wFor Respondent: Ms. Vatsalaa Jha

Section 143(3)Section 144C(1)Section 4Section 5Section 92CSection 92C(1)

respect of fees paid by the Appellant to its AE for technical consultancy services. (a) Rejection of Appellant's Most Appropriate Method The Learned TPO erred in proposing and the Hon'ble DRP further erred in confirming the rejection of Transactional Net Margin Method (TNMM') considered as the most appropriate ... consultancy fees’ with its associated enterprise by applying Transactional Net Margin Method (‘TNMM') as the most M/s. Merck Specialties Pvt. Ltd. ITA No.2056/Mum./2016 appropriate method. During the course of transfer pricing assessment proceedings, assessee was asked to submit the details of the services received under the aforesaid agreement

Ocwen Financial Solutions Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Special Range-5, Bangalore

In the result, the appeal filed by the assessee is partly allowed

ITA 342/BANG/2021[2016-17]Status: DisposedITAT Bangalore14 Oct 2022AY 2016-17

Bench: Shri George George K, Jm & Shri Laxmi Prasad Sahu, Am It(Tp)A No.342/Bang/2021 : Asst.Year 2016-2017 M/S.Ocwen Financial Solutions The Assistant Commissioner Private Limited Of Income-Tax V. Pritech Park, Survey No.51 To Special Range – 5 64/4, Block No.12, Unit 2, 5B & Bangalore. 6A Floors, Bellandur Village, Sarjapur Marathahalli Ring Road Bengaluru – 560 103. Pan : Aaaco3764E. (Appellant) (Respondent) Appellant By : Sri.Ankur Pai & Sri. K.R.Vasudevan, Advocates Respondent By : Sri.K.Sankar Ganesh, Jcit-Dr Date Of Pronouncement : 14.10.2022 Date Of Hearing : 13.10.2022 O R D E R Per George George K, Jm : This Appeal At The Instance Of The Assessee Is Directed Against Final Assessment Order Dated 30.03.2021 Passed U/S 143(3) R.W.S. 144C(13) Of The I.T.Act. The Relevant Assessment Year Is 2016-2017. 2. The Brief Facts Of The Case Are As Follows: The Assessee Is A Company Engaged In Providing It Enabled Services To Ocwen Mortgage Servicing Inc. Usvi. The Assessee Is A Wholly Owned Subsidiary Of Ocwen Asia Holdings Limited, Mauritius. For The Assessment Year 2016-2017, The Return Of Income Was Filed On 29.11.2016 Declaring Total Income Of Rs.93,31,44,800. The Case Was Selected For Scrutiny

For Appellant: Sri.Ankur Pai & Sri. K.R.Vasudevan, AdvocatesFor Respondent: Sri.K.Sankar Ganesh, JCIT-DR

Section 143(2)Section 143(3)

from its AEs in respect of ITES provided. The assessee in its TP study, had selected Transactional Net Margin Method (TNMM) as the most appropriate method and computed its margin at 15.82% on operating cost. As regards the selection of comparables, the assessee carried out search for uncontrolled comparables using ... rejected the TP study and conducted fresh analysis. The TPO, however, agreed with the assessee that TNMM was to be applied as the most appropriate method. The TPO thereafter applied the following filters:- 3 IT(TP)A No.342/Bang/2021. M/s.Ocwen Financial Solutions Pvt.Ltd. Sl. Filters used for ITES segment

Infiniti Wholesale Ltd ( Formerly Knwon As Woolwonths Wholesale (India) P.Ltd), Mumbai vs. Asst CIT Cir 8(3), Mumbai

In the result, appeal filed by the Appellant is partly allowed

ITA 7718/MUM/2012[2008-09]Status: DisposedITAT Mumbai13 Oct 2022AY 2008-09

For Appellant: Shri Nitesh JoshiFor Respondent: Michael Jerald

Section 143(3)Section 144CSection 144C(5)Section 92C

price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner namely:— (a) Comparable uncontrolled price method, by which- (i) The price charged or paid for property transferred or services provided ... rightly submitted the by the ld. Representative for the assessee, when the transaction was compared by taking CUP method as the most appropriate method, the price charged or paid by the assessee for the property transferred needs to be compared in a comparable uncontrolled transaction or a number of such

ACIT, Cir- 14(1)(2), Mumbai vs. Wns Global Services Pvt. Ltd., Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2474/MUM/2021[2013-14]Status: DisposedITAT Mumbai12 Oct 2022AY 2013-14

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 14ASection 32(1)

projections will not hold good when the assessee company has actual results, and therefore benchmarking considering CUP as WNS Global Services Pvt. Ltd., Most appropriate method, where valuation report considered on estimated basis is not acceptable in this case. 8. Whether on the facts and circumstances of the case ... been followed. Whereas, the assessee has followed in its transfer pricing study as the CUP method as the most appropriate method by determining the value of the MSA on the basis of valuation report given by the independent valuer. Section 92C(1) of the Act provides that the international transaction

ACIT, Circle 14 (1)(2), Mumbai vs. Wns Global Services Pvt. Ltd., Mumbai

In the result, appeal filed by the assessee is allowed

ITA 2473/MUM/2021[2014-15]Status: DisposedITAT Mumbai12 Oct 2022AY 2014-15

Bench: Shri Vikas Awasthy, Hon'Ble & Shri S. Rifaur Rahman, Hon'Ble

Section 14ASection 32(1)

M/S. Tivo Tech Private Limited (Formerly Known As Veveo (India) Private Limited), Bangalore vs. Deputy Commissioner of Income Tax, Circle-7(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 237/BANG/2021[2016-17]Status: DisposedITAT Bangalore12 Oct 2022AY 2016-17

Bench: Shri George George K. & Ms. Padmavathy S

For Appellant: Smt. Tanmayee Rajkumar, AdvocateFor Respondent: Dr. Manjunath Karkihalli, CIT(DR)(ITAT), Bengaluru

Section 143(2)Section 234BSection 37

hearing in the following paragraphs 8. The assessee for the purpose of TP study has chosen Transaction Net Margin Method (TNMM) as the Most Appropriate Method (MAM). The Operating Profit divided by the Operating Cost (OP/OC) is the Profit Level Indicator (PLI). The assessee selected 8 comparable companies ... price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— (a) to (d) ….. (e) transactional net margin method, by which,— (i) the net profit margin realised by the enterprise

Csav Group (India) Pvt. Ltd., Gurgaon vs. DCIT, Gurgaon

In the result, appeal by the assessee is partly allowed for statistical purpose

ITA 1941/DEL/2015[2010-11]Status: DisposedITAT Mumbai10 Oct 2022AY 2010-11

Bench: Shri Pramod Kumar & Shri Sandeep Singh Karhail

For Appellant: Shri Rajan R. VoraFor Respondent: Ms. Samruddhi D. Hande

Section 143(3)Section 144CSection 234BSection 271(1)(c)Section 92CSection 92D

Relationship Management (CRM)  Insurance and Claims” 11. As per transfer pricing study report, the assessee used Transactional Net Margin Method (“TNMM”) as the most appropriate method with Profit Level Hapag–Lloyd Global Services Pvt. Ltd. [Successor of CSAV Group (India) Pvt. Ltd.] ITA no.1941/Del./2015 Indicator (“PLI”) of Operating Profit

Softlayer Technologies India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle- 6(1)(2), Bangalore

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 265/BANG/2021[2016-17]Status: DisposedITAT Bangalore10 Oct 2022AY 2016-17

Bench: Shri George George K & Shri Laxmi Prasad Sahu

For Appellant: Shri Padamchand Khincha, C.AFor Respondent: Dr. Manjunath Karkihalli, CIT (DR)

Section 143(3)Section 92C

software development services (SWD) which was selected by the tax payer and by applying certain filters and TNMM is applied as the most appropriate method. On 27/05/2019, a detailed show cause notice was issued to the assessee in respect of Software Development Services segment (SWS). The assessee submitted details ... length price in certain cases. 10CA. (1) Where in respect of an international transaction or a specified domestic transaction, the application of the most appropriate method referred to in sub-section (1) of section 92C results in determination of more than one price, then the arm's length price

Ntt Data Fa Insurance Systems (India) Private Limited, Bangalore vs. The Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 261/BANG/2021[2016-17]Status: DisposedITAT Bangalore03 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.261/Bang/2021 Assessment Year: 2016-17

For Appellant: Shri T. Suryanarayana, Sr. A.RFor Respondent: Shri Sumer Singh Meena, D.R

Section 143(3)Section 92C

external comparison. 3.6 Therefore, since internal CUP is available for a price based comparability analysis, the CUP method was selected as the most appropriate method for determining the ALP of the international transaction. Comparables selected by assessee and the range of weighted average of OP/TC of comparable companies under TNMM ... rival parties and perused the record. The ALP in relating to the international transactions is required to be determined by applying the most appropriate method of transaction, class of transaction or class of associate persons. In the present case, the assessee as well as the TPO had applied Transaction

Hewlett Packard (India) Software Operation Private Limited, 2016-17 vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal filed by the assessee is partly allowed for statistical purposes

ITA 213/BANG/2021[2016-17]Status: DisposedITAT Bangalore03 Oct 2022AY 2016-17

Bench: Shri N.V. Vasudevan & Shri Chandra Poojariit(Tp)A No.213/Bang/2021 Assessment Year: 2016-17

For Appellant: Shri Padam Chand Khincha, A.RFor Respondent: Capt. Pradeep Arya, D.R

Section 133(6)Section 143(3)Section 92C

dated 23.11.2012 wherein this Tribunal took the following view:- “64. The next objection of the Assessee is that when the most appropriate method selected for determining ALP is the TNMM there is no reason as to why one should look at price difference in offshore software development and onsite software ... methods prescribed therein. First proviso to Section 92C(2) clearly provides that when more than one price are determined by the most appropriate method; then the Arm's Length Price shall be taken to be Arithmetic Mean of such prices. It does not talk of excluding companies with high

M/S. Mahindra Homes Pvt. Ltd, Mumbai vs. Addl/Jt/Dy/ACIT/ITO/NFAC, Mumbai

In the result, the appeal of the assessee for Asst Year 2016-17 is partly allowed for statistical purposes

ITA 2179/MUM/2021[2017-18]Status: DisposedITAT Mumbai30 Sept 2022AY 2017-18

Bench: Us That The Issues In Asst Year 2016-17 May Be Taken As The Lead Case & The Decision Rendered Thereon Would Apply With Equal Force For The Asst Year 2017-18 Also In View Of Identical Facts Except With Variance In Figures.

Section 143(3)Section 144C(13)Section 144C(5)Section 92C

CCDs Quarterly Quarterly Payment terms 6.2. The nature of disputed international transaction carried out by the assessee with its AE together with Most Appropriate Method (MAM) adopted by the assessee and details of its margins are tabulated as under:- Margin of Rate/ Margin Nature of the Value of the Method

Mahindra Homes P. Ltd., Mumbai vs. ITO, Range-7(2)(1), Mumbai

In the result, the appeal of the assessee for Asst Year 2016-17 is partly allowed for statistical purposes

ITA 1008/MUM/2021[2016-17]Status: DisposedITAT Mumbai30 Sept 2022AY 2016-17

Section 143(3)Section 144C(13)Section 144C(5)Section 92C

M/S. India Medtronics Pvt.Ltd., Baroda vs. The Dy.CIT., Circle-1(2), Baroda

In the result, similarly the Assessee’s appeal is partly allowed

ITA 480/AHD/2011[2005-06]Status: DisposedITAT Mumbai30 Sept 2022AY 2005-06

Bench: Shri Amit Shukla & Shri Gagan Goyal

For Appellant: Sh. Rajan R. Vora with Sh. Nikhil TiwariFor Respondent: Dr. Yogesh Kamath/ Akhtar Hussain Ansari

Section 234BSection 271Section 274Section 92C

rule 10D (1) of the Income-tax Rules, 1962”. 5. “the learned AO/ TPO erred in selecting Resale Price Method (‘RPM’) as the most appropriate method and in rejecting the Transactional Net Margin Method (‘TNMM’) selected by the appellant”. 6. “the learned AO/ TPO erred in rejecting the certain comparables ... erred in facts and law in upholding the rejection of the 2. Transactional Net Margin Method (‘TNMM’) as the most appropriate method for benchmarking the international transaction of import of goods from AEs made by the transfer pricing officer (‘TPO’)/ Assessing Officer (‘AO’)”. “erred in fact

Ge Be Private Limited, Bengaluru vs. Deputy Commissioner of Income Tax, Circle-3(1)(1), Bangalore

In the result, the appeal by the assessee is partly allowed

ITA 304/BANG/2022[2017-18]Status: DisposedITAT Bangalore29 Sept 2022AY 2017-18

Bench: Shri N. V. Vasudevan & Shri Chandra Poojariit(Tp)A No.304/Bang/2022 Assessment Year : 2017-18 Vs. Dcit, M/S. Ge Be Pvt. Ltd., Circle – 3(1)(1), 60, Export Promotion Industrial Park, Bengaluru. Whitefield, Bengaluru – 560 066. Pan : Aaacg 6714 A Assessee Respondent Assessee By : Shri. Aliasgar Rampurawala, Ca Revenue By : Shri. Sumer Singh Meena, Cit(Dr)(Itat), Bengaluru Date Of Hearing : 27.09.2022 Date Of Pronouncement : 29.09.2022 O R D E R Per N V Vasudevan

For Appellant: Shri. Aliasgar Rampurawala, CAFor Respondent: Shri. Sumer Singh Meena, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(13)Section 92(1)Section 92B(1)

Study) to justify the price paid in the international Transaction as at ALP by adopting the Transaction Net Margin Method (TNMM) as the Most Appropriate Method (MAM) of determining ALP. The assessee selected Operating Profit/Operating Cost (OP/OC) as the Profit Level Indicator (PLI) for the purpose of comparison. The OP/OC ... price in relation to an international transaction [or a specified domestic transaction] shall be determined by any of the following methods, being the most appropriate method, in the following manner, namely :— (a) to (d).... IT(TP)A No.304/Bang/2022 Page 7 of 18 (e)transactional net margin method, by which

Hp Pps Services India Private Limited, Bangalore vs. Assistant Commissioner of Income Tax, Circle-3(1)(2), Bangalore

In the result the appeal filed by the assessee stands partly allowed

ITA 278/BANG/2021[2016-17]Status: DisposedITAT Bangalore29 Sept 2022AY 2016-17

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuit(Tp)A No. 278/Bang/2021 Assessment Year : 2016-17 M/S. Hp Pps Services India Pvt. Ltd., The Deputy No. 24, Salarpuria Commissioner Of Arena, Income Tax, Hosur Main Road, Circle 3 (1)(1), Adugodi, Vs. Bangalore. Bangalore – 560 030. Pan: Aadch5825N Appellant Respondent : Shri Padamchand Assessee By Khincha, Ca : Shri Binod Kumar Singh, Revenue By Cit Dr Date Of Hearing : 22-08-2022 Date Of Pronouncement : 29-09-2022 Order Per Beena Pillaipresent Appeal Is Filed By Assessee Against Assessment Order Dated 29/03/2021 Passed By National E-Assessment Centre, Delhi For A.Y. 2016-17 On Following Grounds Of Appeal. “The Appellant Submits That: I. Transfer Pricing The Grounds Mentioned Hereinafter Are Without Prejudice To One Another. 1. The Learned Assessing Officer ('Learned Ao'), Learned Transfer Pricing Officer ('Learned Tpo') & The Honourable Dispute Resolution Panel ('Hon'Ble Drp')

For Respondent: Shri Padamchand

SWD/ITeS segments provided to the associated enterprises (AE) has been determined by applying Transactional Net Margin Method (TNMM), stating to be the most appropriate method in the facts and circumstances of the case. The operating profit to operating cost ratio has been taken as the profit level indicator

M/S Herbalife International India Pvt Ltd, Bangalore vs. Assistant Commissioner of Income Tax Circle-11(4), Bangalore

In the result, both the appeals filed by assessee stands allowed for statistical purposes

ITA 2068/BANG/2017[2005-06]Status: DisposedITAT Bangalore29 Sept 2022AY 2005-06

Bench: Smt. Beena Pillai & Shri Laxmi Prasad Sahuassessment Year : 2003-04 M/S. Herbalife International India The Deputy Pvt. Ltd., Commissioner Of #14, Pardhanani Income Tax, Wilshire, Circle – 11(4), Commissariat Road, Vs. Bangalore. Bangalore – 560 025. Pan: Aaach8025R Appellant Respondent & Assessment Year : 2005-06 M/S. Herbalife International India The Assistant Pvt. Ltd., Commissioner Of #14, Pardhanani Income Tax, Wilshire, Circle – 11(4), Commissariat Road, Vs. Bangalore. Bangalore – 560 025. Pan: Aaach8025R Appellant Respondent : Shri Padam Chand Assessee By Khincha, Ca Revenue By : Shri Arun Kumar, Cit Dr Date Of Hearing : 06-09-2022 Date Of Pronouncement : 29-09-2022

For Respondent: Shri Padam Chand

Section 250Section 253

length price for testing the goods exported to AE without appreciating the business and economic factors. 5. Unlawfully presumed estoppel on choice of most appropriate method and unjustly insisted on CUP contrary to law ignoring alternative analysis. Page 3 of 29 ITA Nos. 2067 & 2068/Bang/2017 International transaction relating to payment ... appreciating the commercial expediency of payment of administrative fees by the Appellant. 3. Erred in rejecting Transactional Net Margin method ("TNMM") as the most appropriate method to determine the arm's length price of the international transaction of payment of administrative fees by the Appellant. 4. Erred in considering

M/S Herbalife International India Pvt Ltd, Bangalore vs. Deputy Commissioner of Income Tax Circle-11(4), Bangalore

In the result, both the appeals filed by assessee stands allowed for statistical purposes

ITA 2067/BANG/2017[2003-04]Status: DisposedITAT Bangalore29 Sept 2022AY 2003-04

For Respondent: Shri Padam Chand

Section 250Section 253

DCIT 27(1), Mumbai vs. Gopuram Developers, Mumbai

In the result, the appeal filed by the Revenue is accordingly dismissed

ITA 1408/MUM/2022[2013-2014]Status: DisposedITAT Mumbai28 Sept 2022AY 2013-2014

Section 133ASection 143(3)

underestimation of profit by the impugned method of accounting adopted by the Appellant and how the method adopted by the A.O is most appropriate method as per the facts of the case. In the present case the A.O. during the course of Assessment Proceedings had simply issued show cause notice