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Totgar'S Co-Op.Sale Sty.Ltd vs Income-Tax Officer,Karnataka on 8 February, 2010 Equivalent citations

Totgars Co-Op Sale Society Ltd vs The Income Tax Officer Ward-1 on 30 September, 2008 Bench: V.G Sabhahit , S.N.Satyanarayana

material cost) Revised Profit 111,763,720 Adjusted OP/ Sales 10.69% ITA No.2210/Ahd/2012 (By Assessee) and ITA No.2154/Ahd/2012

under: Name of the company Database GP/Sales OP/Sales A&M/Sales VAE/Sales Pebco Motors Ltd. P 6.62% -3.84% 1.20% 10.46% Popular ... Comparables' Arm's Length Result GP/Sales 27.36% 13.65% OP/Sales 13.52% 2.11% 1.43 As discussed above, since at both gross as well

expenses 24,773.04 7.012.86 Operating profit 209.10 2,723.19 OP/OC 0.84% 38.83% OP/Sales 0.72% 27.97% 3.2 In order to benchmark the international transactions ... expenses Operating 209.10 2,723.19 -5929.84 -2997.55 profit OP/OC -4.66% OP/Sales -4.89% On the basis of above analysis and it is proposed

Margin Method ("TNMM") considering Operating Profit/ Sales ("OP/Sales") as Profit Level Indicator ("PIT). A structured benchmarking process was carried ... reflected in the TP Study report, identifying 7 comparables having average OP/Sales of 8.85%, whereas OP/Sales of the tested party i.e. Manufacturing

profit level indicator (PLI) for class I transactions and operating profit/sales (OP/Sales) was chosen as the relevant profit level indicator for class ... with its AEs are on cost side, hence in better comparability OP/sales is to be used as the PLI. He held further that

2022 /AY.18-19 M/s Gondal Taluka Co-Op Sales & Purchase Union Ltd. IN THE INCOME TAX APPELLATE TRIBUNAL, RAJKOT BENCH, RAJKOT BEFORE ... 2022 /AY.18-19 M/s Gondal Taluka Co-Op Sales & Purchase Union Ltd. 2. The learned Assessing Officer has erred

TNMM analysis for buying services are summarized as under: Average OP/ Sales % of comparable companies 9.68% OP/ Sales % of assessee from buying services 23.96% Since ... companies having average operating profit margin (OP/OC) at 10.57%: S.No. Name of the company OP/Sales OP/OC 1. Raymond Apparel Limited

adopted TNMM as the most appropriate method but used OP/Sales (as against OP/TC adopted by the TPO and OP/CE adopted ... against OP/TC adopted by the TPO in the first round of litigation. We find the CIT(A) directed for adoption OP/ Sales