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2016 (1) TMI 1260 - AT - Income TaxTPA - selection of comparable - Held that:- Functionally dissimilar and are having product lead revenues, extra ordinary events, different risk profile and application of wrong filters compnaies to be excluded form comparability. Claim of the assessee on working capital adjustments - Held that:- We find that the assessee made detailed submissions before the lower authorities on this issue, which we do not extract for the sake of brevity. Suffice to say that the contentions raised by the assessee have not been dealt with by the TPO as well as the DRP properly and assessee to needs to be provided one more opportunity in the interest of justice for proving its case for working capital adjustments. The propositions of law laid down by the Tribunals on the issue of working capital adjustment in ITes and IT segment deserves to be considered by TPO. Thus, it would be appropriate to set aside the matter to the file of the Assessing Officer/T.P.O. for fresh adjudication, in accordance with law on the issue of claim of the assessee on working capital adjustments.
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