Case Law Details
Toyota Kirloskar Motor (P) Ltd Vs ACIT (ITAT Bangalore)
The Appellant submits the in its own case for AY 2003-04, the Honourable Bangalore Tribunal has accepted that TP adjustment has to restricted to AE transactions. Further, in Appellants own case for AY 2013-14 [ITA No.2016/Bang/2018, dated 18.08.2021], the Honourable Bangalore Tribunal has upheld the action of CIT(A) in directing the TPO to restrict TP adjustment to AE transactions.
A similar issue has been decided by us in assessee’s own case for the assessment year 2012-13 and the result mutatis mutandis shall apply to assessment year 2014-15.
FULL TEXT OF THE ORDER OF ITAT BANGALORE
These appeals filed by the assessee are directed against separate Final Assessment order passed by the AO, Bangalore dated 22.11.2016 and 24.12. 2018 for the assessment year 2012-13 and 2014-15 respectively.
Please become a Premium member. If you are already a Premium member, login here to access the full content.
