Case Law Details
Puma Sports India Pvt. Ltd. Vs JCIT (OSD) (ITAT Bangalore)
ITAT Bangalore held that rule 10B(2)(d) of the Income Tax Rules provide that the company is in the wholesale trading and retail trading have to be considered separately for the purpose of comparison.
Facts-
The case was selected for scrutiny and reference was made to the Transfer Pricing Officer (TPO) to determine the arm’s length price (ALP) of the international transactions the assessee had with its associated enterprises (AE). AO determined a TP adjustment of Rs.6,65,42,022/-. Aggrieved, the assessee raised its objections before the DRP.
DRP vide its directions dated 27.09.2019 directed the TPO to exclude the liabilities of the earlier years and to include sample sale group sale venture discount received out of miscellaneous income while computing operating income. Accordingly the TP adjustment was revised by the TPO to Rs.6,59,34,345/. The assessee filed an appeal before the Tribunal against the final assessment order passed giving effect to the directions of the DRP. Being aggrieved, the present appeal is filed.
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