TP – ALP needs to be seen only with regard to transaction with AEs

TP – ALP needs to be seen only with regard to transaction with AEs Posted: 30 Nov 2012 11:08 PM PST The profit margin from the international transaction with the A.E. has to be seen in relation to the uncontrolled transaction with the independent parties. What is to be compared is the international transactions of the assessee with its related parties and not for its entire transaction with... TP – Super profit companies cannot be considered as comparable Posted: 30 Nov 2012 10:57 AM PST Working given by the TPO shows that it is earning 7% commission, whereas as per the industry policy as decided by the AAAI the service on media agency earns commission of 2.5%. On that reason also, since it is an extreme case of earning 7% commission (in our view it is wrongly considered), on the... Maintenance of DG sets is prima facie input service Posted: 30 Nov 2012 10:45 AM PST Learned CA submits that the maintenance of DG sets is essentially and integrally connected to rendering the business and no export of service can take place if there is no uninterrupted power supply and, therefore, the said services should be treated as 'input services'. We are prima facie, in...