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
order to benchmark its international transactions
compared its entity level margin (OP/Sales) with external
comparable and computed its margin at 1.06% as against margin ... Method
(TNMM) as the Most Appropriate Method (MAM) with Operating
Profit / Sales (OP/Sales) as the Profit Level Indicator (PLI) for
benchmarking at entity level
under:
Manufacturing Segment:
SI .
No. Comparables' Name Sales OP OC OP/OC OP/Sales
1 Amtech Power ... Trading Segment:
Sl
Company Name Sales OP OC OP/OC OP/Sales
No
1 Cuprum Bagrodia
respect of challenging PLI as OP/Sales and
various constituents of the PLI (Profit Level Indicator) which has been disputed by the
TPO/AO.
Assessee ... sales/Total Sales >65% was selected 68
Companies with positive net worth were selected 60
Export Sales Total Sales >50o% was selected
Gross Profit/
Sales (GP /Sales) as the relevant Profit Level Indicator (,PLI')
and substituting the same with Operating Profit/ Sales (OP
/Sales) to ascertain ... Gross Profit/
Sales (GP /Sales) as the relevant Profit Level Indicator CPLI')
and substituting the same with Operating Profit/ Sales (OP
/Sales) to ascertain
OP-2 is a 100% subsidiary of OP-1 through Esaote International N. V.
C. No. 09 of 2016 15
Thus, OP-1 and OP ... made by OP Group
concluded that OP-1 has entered into in an agreement with OP-2 giving
exclusive rights to OP
Uttar Gujarat Vij Company Ltd. & vs Agahr Group Co.Op.Cotton Sale Ginning ... on 25 January, 2018
Author: R.Subhash Reddy
Bench: R.Subhash ... COMPANY LTD. & 1....Applicant(s)
Versus
AGAHR GROUP CO.OP.COTTON SALE GINNING & PRESSING
SOC.LTD.....Respondent(s)
==========================================================
Appearance:
MS LILU
Kapadvanj Co-Op. Cotton Sale ... vs Hima Enterprise'S Owner @ Proprietor on 18 January, 2018
Author: A.J. Shastri
Bench: A.J. Shastri ... FIRST APPEAL (STAMP NUMBER) NO. 3538 of 2017
==========================================================
THE KAPADVANJ CO-OP. COTTON SALE GINNING AND PROCESS
SOCIETY LTD.,....Applicant(s)
Versus
HIMA ENTERPRISE
page 12 of the TPO's order, that the OP/Sales margin of the
assessee is -59.46%. The TPO adopted Dies and Tools ... OP/Sales at 6.58% and 12.92% and
OP/TC at 7.01% and 11.44% respectively. The average OP/Sales was thus computed at
9.75%, and OP
most appropriate method and operating profit to
operating revenue (OP/Sales) was taken as the Profit Level Indicator
(PLI). In the said TPO Study Report ... five comparables was selected having an
average (OP/Sales) of 6.19%. Since the OP/Sales of the assessee-company
as worked at 8.41% was higher
