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2018 (2) TMI 1975 - ITAT BANGALORETPA - comparable selection - HELD THAT:- Referring to software development activity and applying CUP Method as the Most Appropriate Method ('MAM') companies functionaly dissimilar with that of assessee need to be deselected from final list. Selection of MAM - TPO in rejecting CUP Method adopted as the MAM by the assessee for its TP Study and adopting TNMM as the MAM for carrying out the comparability analysis - As relying on own case [2016 (6) TMI 1322 - ITAT BANGALORE] we decide the issue against the assessee and confirm the order of the TPO in adopting TNMM as the MAM. Consequently, ground No.2 of the assessee's appeal is dismissed. Risk adjustment - Since the assessee has not given the computation of risk adjustment of the assessee vis-à-vis the comparable companies, we hold that the assessee shall not be entitled to any risk adjustment and accordingly reverse the DRP's decision granting the assessee risk adjustment Charging of Interest u/s. 234B & 234D - HELD THAT:- The charging of interest is consequential and mandatory and the Assessing Officer has no discretion in the matter.
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