Case Law Details
Case Name : Toyoda Micromatic Machinery India Private Ltd. Vs DCIT (ITAT Delhi)
Related Assessment Year : 2011-12
Courts :
All ITAT ITAT Delhi
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Toyoda Micromatic Machinery India Private Ltd. Vs DCIT (ITAT Delhi)
It is a fact that the learned assessing officer has not challenged the order of the learned CIT – A stating that resale price method is the most appropriate method as assessee does not engage in any deemed manufacturing or further value addition. It is also the method selected by assessee as MAM. Therfore only issue is how to compute PLI when RSP Method is applied in this peculiar case. According to the provisions of rule 10 B for the determination of the arm’s-length price u/s 92C, the resale price method computation shal...
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