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2016 (6) TMI 1309 - ITAT DELHITPA - comparable selection - functinal similarity - Held that:- Companies functionally dissimilar with that of assessee ICC India as providing IT-enabled services including data processing, data archiving, coding, Comp setting for Internet, etc. ICC India handles everything from LaTeX, Quark and FrameMaker composition to technical illustration and eBook conversion need to deselected from final list. It has been noted by the DRP that the margin has been wrongly taken at 1.73% instead of 12.58%. However, the DRP has somehow omitted giving the directions to remove the inaccuracy. Accepting the assessee’s plea we direct the TPO to recompute use the PLI of the assessee as discussed in detail in pages 21-23 of the DRP order after duly factoring the impact of prior period depreciation of ₹ 89,74,100/-, increase in stock of ₹ 38,80875/- and ₹ 27,02,513/- on account of other income after affording a proper opportunity to the assessee to support its claim. It is also the assessee’s contention that the working capital adjustment has been reduced from 3.64% to 2.18% without providing any details. In this regard also, the TPO is directed to re-compute the working capital adjustment after giving a proper opportunity to the assessee to submit its working and objections
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