Not a Wholesale Trader: 3% Tolerance Adopted – Karnataka HC in TP Case

PCIT Vs Toyota Tsusho India Private Limited (Karnataka High Court)

Karnataka High Court held that for AY 2014-2015, assessee couldn’t be classified as wholesale trader as both the specified conditions are not satisfied. Accordingly, in terms of notification no. 30/2013 tolerance range of 3% to be adopted.

Facts- The Assessee is trading in automobile components, processing of steel products and providing logistic services, primarily catering to the automotive industry. During the year, in trading segment, TPO also rejected the transfer pricing studies and d

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