Friday, July 22, 2011

Section 92C(2) specifies that adjustment of 5% is not applicable if a singl

Section 92C(2) specifies that adjustment of 5% is not applicable if a single price is determined by assessee

Income-tax : Where the ALP has been determined by applying only one out of the several methods specified under section 92C(1) the assessee is not entitled for deduction of 5% adjustment from the ALP as stipulated under section 92C(2) [Section 92C of the Income-tax Act, 1961 - Transfer Pricing] - [2011] 10 taxmann.com 160 (Hyd. - ITAT)

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