GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE

In the result, the revenue’s appeal is dismissed and the assessee’s appeal is partly allowed

Bench: Smt. P. Madhavi Devi & Shri Abraham P George

Method (CPM). In the absence of such adjustment, a mere application of CPM on comparables with different functional profile will not be in tune with the TP Rules. Therefore, as CPM is adopted as the MAM, the assessee should be allowed adjustment on actual basis, which will reliable and accurate, as stipulated in Rule 10C(2). Needless

GE MEDICAL SYSTEMS INDIA PRIVATE LIMITED,BANGALORE vs. DCIT, BANGALORE