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2012 (12) TMI 1060 - ITAT MUMBAITransfer pricing adjustment on account of provisions of technical services - selection of comparables - Held that:- Assessee received income on account of application research and technical services from its parent company, which are international transactions as defined u/s 92B, thus companies dissimilar with that of assessee need to be deselected from final list. Exclusion of the comparables due to high profit margin or loss, we find that the action of the TPO excluding the two comparables on the ground that these companies are persistent loss making concluded merely on the basis of two years data and without going into the details whether the loss is because of factors as prescribed under Rule 10B(2) r.w. sub rule (3) is not justified. Disallowance in respect of global support service charges - Held that:- There is no dispute that the agreement between the parties was entered into during the year relevant to assessment under consideration and the debit note in respect of the expenses was also received during the year under consideration therefore, the expenditure has been crystallised during the year under consideration. The CIT(A) has allowed the claim of the assessee by considering both the AYs . Therefore, in the facts and circumstances of the case, we do not find any error or illegality in the order of the CIT(A),
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