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| The Tax Publishers2021 TaxPub(DT) 0147 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
In case of assessee having rendered business facilitation services to its AE abroad, considering argument of assessee that it would be well within the +5% tolerance range after inclusion of Icra Online Ltd., in the final list of comparables, TPO was directed to include the same in final list of comparables.
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Transfer pricing - Determination of ALP - Selection of comparables -
Assessee rendered business facilitation services to its AE abroad. TPO suggested ALP adjustment. Assessee submitted that if ICRA Online Ltd alone was included in the final list of comparables chosen by the TPO, assessee would be well within + 5% tolerance range permitted in the statute and hence, no adjustment would be required to be made to international transaction of assessee. Held: Considering argument of assessee that it would be well within the +5% tolerance range after inclusion of ICRA Online Ltd., in the final list of comparables, TPO was directed to include the same in final list of comparables.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
IN THE ITAT, MUMBAI BENCH
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