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The Tax PublishersIT (TP) A Nos. 213/Bang/2017 and 2331/Bang/2016
2020 TaxPub(DT) 4694 (Bang-Trib)INCOME TAX ACT, 1961
Section 92C
In respect of TP adjustment under the licensed manufacturing segment being exchange fluctuation, bank charges, interest charges and management fee, assessee should establish categorically based on cogent materials/evidences of how it should not be considered as operating for the purposes of computing margin of licensed manufacturing segment
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Transfer pricing - Computation of ALP - TP Adjustment under licensed manufacturing segment -
Assessee filed appeal against the order of TPO making TP adjustment under the licensed manufacturing segment being exchange fluctuation, bank charges, interest charges and management fee. Held: In respect of bank charges, interest charges, management fees assessee should establish categorically based on cogent materials/evidences of how it should not be considered as operating for the purposes of computing margin of licensed manufacturing segment. Assessee was, therefore, directed to file all relevant documents/evidences/information necessary to establish its claim in respect of aggregation/segregation of the costs alleged in the order passed by TPO. Thus, matter was remanded to TPO for de novo assessment as per Transfer Pricing provisions in accordance with law.
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2011-12
IN THE ITAT, BANGALORE BENCH
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