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2014 (10) TMI 862 - AT - Income TaxAddition on a/c of adjustment of arm’s length price - CIT(A) deleted the addition - selection of comparable - Held that:- Considering the judicial precedent that the finding arrived at in the impugned order deserves to be upheld as to exclude Vishal Technologies as a comparable. The fact remains that Vishal has a different business model is a consistent fact on record qua the said comparable which finding has not been rejected by the Revenue. Working capital adjustment - Held that:- The assessee consistently has sought right from the assessment stage the adjustments for working capital deployment in its comparables, the working has been placed before the AO and again before the CIT(A). Whereas ld. AO on principle held it to be not allowable, the CIT(A) considering the same has come to the finding under challenge by the Revenue. Apart from the general argument which on facts is found to be not correct no infirmity in the working accepted by the CIT(A) has been brought to our notice. In the aforementioned peculiar facts and circumstances being satisfied by the finding arrived at which has been reproduced in the earlier part of this order, we dismiss the departmental ground.
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