Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (6) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (6) TMI 153 - ITAT DELHIDetermination of arm's length price - selection of comparables - Held that:- The matter is restored to the file of Ld. TPO for re-characterization of profile of the assessee and making fresh selection of comparables functionally similar to the assessee and then decide the arm’s length price of the international transaction accordingly - also assessee should be given adequate opportunity of being heard - allowed partly for statistical purposes. Disallowance u/s 40(a)(i) for non-deduction of tax at source on inter-company fee payments - Held that:- Ld. DRP has confirmed the disallowance without any detailed reasoning and taking into account the documentary evidences of deposit of tax - thus it is decided to restore this issue to the file of the Ld. AO for deciding afresh after providing adequate opportunity of being heard to the assessee - allowed for statistical purposes.
|