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2022 (1) TMI 1045 - ITAT DELHITP Adjustment - Comparable selection - HELD THAT:- Axis Integrated System Ltd. be excluded from the list of comparables as not functionally similar, engaged in addressing regulatory and licensing requirements and acts as a liaison between all related Government and regulatory agencies and providing specialized consultancy services. Excludability of HSCC (India) Ltd. - On a careful consideration of the orders of the authorities below in the light of the material available on record, we are of the considered opinion that the provision of the professional consultancy services in healthcare and other social sector has to be compared with the functions performed by the assessee, and that aspect needs proper verification as the data before us cannot convey as to how this comparable has to be excluded or included. Therefore, it will be appropriate to remand the issue relating to its comparability to the file of the Ld. TPO/learned Assessing Officer for thorough verification and if found to have been performing different functions, the same should be excluded from the list of comparables, after hearing the assessee. Computation of the working capital adjustment - As computation of the working capital adjustment was not properly done and the same has to be done in accordance with the ALP margins, and accordingly directed the TPO/learned Assessing to re-compute the working capital adjustment as per the ALP margins, after affording an opportunity to the assessee of being heard. Both the counsel submitted that the same course may be adopted for this year also. Recording the same, we restore this issue to the file of the Ld. TPO/learned Assessing Officer to re-compute the working capital adjustment as per the ALP margins, after hearing the assessee.
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