https://www.taxtmi.com/caselaws?id=257679 The High Court held that the ITAT's order directing a fresh determination of the addition on account of Arm's Length Price for the Assessment Years 2007-08 and 2008-09 was incorrect. The Court emphasized that the cost base should be determined based on the functions performed and costs incurred by the assessee, not by unrelated third-party vendors. The Court referred to the Li and Fung India Pvt. Ltd. judgment and remanded the matter to the AO for redetermination of the cost base in line with the legal provisions. The Court dismissed the appeals, upholding the ITAT's decision for a proper interpretation of the cost base. en-us Wed, 11 Mar 2015 00:00:00 +0530 Thu, 19 Mar 2015 07:58:09 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=257679 The High Court held that the ITAT's order directing a fresh determination of the addition on account of Arm's Length Price for the Assessment Years 2007-08 and 2008-09 was incorrect. The Court emphasized that the cost base should be determined based on the functions performed and costs incurred by the assessee, not by unrelated third-party vendors. The Court referred to the Li and Fung India Pvt. Ltd. judgment and remanded the matter to the AO for redetermination of the cost base in line with the legal provisions. The Court dismissed the appeals, upholding the ITAT's decision for a proper interpretation of the cost base. Case-Laws Income Tax Wed, 11 Mar 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=257679