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Controlled Cant Benchmark Controlled – Pro-Rata Commission TP Struck Down
Case Law Details
- Case Name
- Honda Trading Corporation India Pvt. Ltd Vs DCIT/ACIT (ITAT Delhi)
- Appeal Number
- Only available for paid members
- Date of Judgement/Order
- Only available for paid members
- Related Assessment Year
- 2021-22
- Courts
- All ITAT, ITAT Delhi
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Honda Trading Corporation India Pvt. Ltd Vs DCIT/ ACIT (ITAT Delhi)
ITAT Delhi partly allowed the assessee’s appeal for AY 2021-22 in Honda Trading Corporation India Pvt. Ltd., deleting TP adjustment of ₹2.57 crore on commission paid, while noting that the large trading-segment TP adjustment of ₹11.58 crore already stood rectified to NIL u/s 154.
The impugned ₹2.57 crore adjustment arose solely from DRP’s vague direction to “verify” why commission paid on exports (2.05%) was higher than commission received on imports (0.59%). Acting on this, the TPO applied a pro...
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