BG EXPLORATION & PRODUCTION INDIA LIMITED,MUMBAI vs. THE DEPUTY COMMISSIONER OF INCOME TAX DDIT/ADIT (INTERNATIONAL TAXATION ) CIRCLE-1, DEHRADUN
In the result, the appeal of the assessee is partly allowed
ITA 7/DDN/2021[2016-17]Status: DisposedITAT Dehradun14 Dec 2021AY 2016-17
Bench: Shri R.K. Panda & Shri V.P. Raoassessment Years: 2016-17
For Appellant: Sh. Ajay Vohra, Sr. AdvocateFor Respondent: Sh. N.S. Jangpangi, CIT/DR
Section 143(3)Section 144C(13)Section 144C(5)Section 44C
transfer pricing adjustment of Rs.2,28,48,22,523 in total towards international transactions pertaining to payment of management service and unit charges, IM charges and payroll expenses to its AE.
Ground No. 2: Erroneous rejection of Transactional Net Margin
Method ("TNMM”) and selection of Comparable Uncontrolled
Price ("CUP”) Method
2.1. The learned TPO / AO / DRP / have erred
