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2017 (11) TMI 1636 - ITAT PUNETPA - Excluding the comparables selected - Held that:- Assessee was engaged in the business of designing and development of chip, integrated circuits and storage components and allied services for its holding company AMCC, USA. Companies Comparable for design engineering segment should be selected as comparable to assessee. Claim of risk adjustment - Held that:- We direct the Assessing Officer to allow risk adjustment and re-work the margins of comparables, in turn, relying on the ratio laid down by the Delhi Bench of Tribunal in the case of Sony India Pvt. Ltd. (2008 (9) TMI 420 - ITAT DELHI-H) and compute the TP adjustment, if any, in the hands of assessee. Setting off of unabsorbed depreciation before allowing deduction under section 10A of the Act - Held that:- We direct the Assessing Officer to allow the deduction under section 10A of the Act before setting off of unabsorbed depreciation against the profits of eligible units. Thus, the ground of objection No.2.4 is allowed in favour of assessee.
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