2020 (12) TMI 1366

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....urana, C.A. For the Revenue : Shri G. Guruswamy, CIT (D.R). ORDER PER SHRI CHANDRA POOJARI, A.M. : This appeal filed by the assessee is directed against the order of Assessing Officer dt.03.09.2018 for the Assessment Year 2014-15 passed u/s.143(3) r.w.s. 144C(13) of the Income Tax Act, 1961 ('the Act'). 2. The assessee has raised various grounds with regard to Transfer Prici....

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....r US entities consequent to MAP Resolution and acceptance. In view of the above submissions of the A.R., we are inclined to allow withdrawal of TP grounds in relation to US entities and dismiss these grounds as withdrawn. 3. Further the assessee filed additional grounds as follows : " That the learned Transfer Pricing Officer, the ld. DCIT, Circle 7(1)(1), Bangalore and the Dispute Res....

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....he ld. DR has no serious objection in admitting the additional ground. 5. We have heard both the parties on admission of the additional ground. In view of the judgement of the Hon'ble Supreme Court in the case of NTPC Ltd. Vs. CIT 229 ITR 383 (SC), we are inclined to admit the additional ground for adjudication. 6. The facts relating to this additional ground are that the in the distribu....

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....lso do assembling of cutting tools. Each assembly consists of putting 20-30 components. Accordingly, the TPO rejected RPM method to determine the Arm's Length Price (ALP) and followed TNMM method. Now the contention of the ld. AR is that the RPM method is most suitable method to determine the ALP of the transaction. He submitted that he could give segmental details of the traded goods and in respe....