ALP & Resultant excess profit to be treated as deemed income under ‘other sources’: HC

CIT Vs Tweezerman (India) Private Limited (Madras High Court) Conclusion: Since there was close association between the seller and the buyer and their ‘arranged’ pricing were adequately substantiated by TPO / AO / CIT(A), therefore, that part of the CIT(A)’s order was upheld which confirmed in toto AO ‘s order as regards the ALP and the resultant excess profit to be treated as deemed income under ‘other sources’. Held:  Assessee-company was a manufacturer of beauty products such as Tweezers, cuticle pushers, etc, and was 100% Export Oriented Unit (EOU). AO ...