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2018 (8) TMI 656 - ITAT DELHITransfer pricing - Assessment u/s 144C r.w.s 143(3) - returned income of Rs. Nil after setting off of brought forward losses - adjustments twoards alleged difference in the arm’s length price of the international transaction of provision of software development services - disregard to the internal benchmarking undertaken by the appellant. Held that:- There is no dispute that the facts and circumstances in the present assessment year are similar to the facts and circumstances as obtaining in the preceding assessment years. The revenue has not placed before us any material so as to enable us to take a different view in the matter. In view of these facts and circumstances, respectfully following the order for earlier assessment years noted above, we restore this matter to the file of the AO/TPO with similar directions as have been given by the ITAT in the preceding assessment year Appeals of the assessee are allowed for statistical purposes.
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