3F INDUSTRIES LIMITED,TADEPALLIGUDEM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE-1, , ELURU
In the result, appeal filed by the assessee is partly allowed for statistical purposes
ITA 54/VIZ/2019[2013-14]Status: DisposedITAT Visakhapatnam15 Dec 2022AY 2013-14
Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble
For Appellant: Sri Suvibha NolkhaFor Respondent: Sri MN Murthy Naik, CIT-DR
Section 143(1)Section 143(3)Section 154Section 92C
747/-.
b) Rejecting comparable uncontrolled Price (CUP) method as the most appropriate method of determining the ALP of purchase of raw materials or semi-finished goods or finished goods and by products with related parties by applying transaction Net Margin Method (TNMM).
c) Not considering the prices published by Department of Horticulture,
Government of Andhra
Pradesh for determination