comparable companies

The Delhi Tribunal, in the case of Global Vantedge Pvt. Ltd. (Taxpayer) [2010-TIOL¬24-ITAT-DEL], has held that the total amount of adjustment made, along with the arms length price (ALP) already reported by the Taxpayer, cannot exceed the total amount of revenues earned by the Taxpayer and its associated enterprise (AE) from dealing with third party clients. Full Article

In the case of Schefenacker Motherson Ltd v. ITO, ITA No. 4459/DEL/07 for AY 2003-04 and schefenacker Motherson Ltd v. DCIT, ITA No.4460/DEL/07 for AY 2004-05, the Delhi Bench of the Income-tax Appellate Tribunal (the Tribunal), held that cash profit on sales “CP/Sales” or cash profit on total cost excluding depreciation “CP/TCdep” can be adopted as an appropriate profit level indicator (PLI) under Transactional Net Margin Method (TNMM), to adjust for material d.. Full Article