The assessee is not entitled to adjustment of 5 per cent as stipulated u/s 92C(2), where only one of the several methods specified u/s 92C(1) is applied by the assessee to determine the ALP

The assessee is not entitled to adjustment of 5 per cent as stipulated u/s 92C(2), where only one of the several methods specified u/s 92C(1) is applied by the assessee to determine the ALP Executive Summary :- The Kolkata Bench ‘B’ of the Income Tax Appellate Tribunal (the “Tribunal”), on 19 November 2010, pronounced its ruling in the case of M/s J J Spectrum Silk Ltd Vs DCIT, Kolkata, ITA No. 625/Kol/2009 , on whether the Taxpayer is entitled to the adjustment of 5 per cent as stipulated u/s 92C(2) of the Income Tax Act, 1961 (the “Act”), where a single arm’s length price has b...