MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed

Bench: Shri Duvvuru Rl Reddy & Shri Rajesh Kumar

50,64,220/-. It is observed from records that the Transfer Pricing Officer (TPO) had adopted Transactional Net Margin Method (TNMM) in respect of the concerned transactions. The TPO had proposed downward adjustment of Rs. 1,45,08,356/-and the same amount was added back by the AO. The Appellant contends that it had adopted Comparable Uncontrolled Price

MAHALAXMI CONTINENTAL LIMITED,GUWAHATI vs. INCOME TAX OFFICER (DCIT/ACIT CIR-1), GUWAHATI

In the result, both the appeals of the assessee are allowed