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2012 (5) TMI 613 - AT - Income TaxTPA - ALP determination - costs are incurred during normal business operations - assessee demonstrated as to the Comparable Companies did not have to incur any such expenses - Held that:- he Assessee ought to succeed on this Ground and we accordingly direct the AO/TPO to examine the claim of the assessee in the light of the directions contained in the order of the Tribunal in the case of Demag Cranes& components (India) Pvt. Ltd (2012 (1) TMI 60 - ITAT Pune ) Working capital adjustment - Held that:- The plea of the assessee has to be upheld in principle. So, however, as the issue has not been examined by the lower authorities, we therefore, deem it fit and proper to restore the issue back to the file of the AO/TPO with direction to examine the claim of the assessee relating to working capital adjustment and eliminate such difference, if any, as are likely to materially affect the profit margins, Deduction under section 10B - Held that:- We set-aside the matter back to the file of the Assessing Officer to ascertain the appropriate amount of communication and insurance expenses that are attributable to export outside India so as to be excludible from the figure of ‘export turnover’ as well as total turnover, and thereafter rework the deduction under section 10B
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