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        Case ID :
        Income Tax

        TP adjustment - The TPO has not given any reason as to why he...

        TPO's Adjustments Rejected: Export Division's Higher Profit Margin Confirms Transactions at Arm's Length, No TP Adjustment Needed. 'sLength.

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                TP adjustment - The TPO has not given any reason as to why he altered the aggregate amount of Net profit. Hence the workings made by TPO is liable to rejected. We have noticed that the net profit margin worked out by the assessee in "Domestic - Personal care division" was 12.31%. The net profit margin worked out for "Exports to AEs" was 24.03%. Hence the net profit margin earned in the exports to AEs division is higher than its comparable "Domestic - Personal care division". Hence it has to be held that the international transactions of making exports to AEs are at arms length and hence no T.P adjustment is called for. - AT
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