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2012 (9) TMI 1003 - AT - Income TaxDeduction u/s. 10A before setting off unabsorbed business losses/depreciation carry forward losses from the earlier years allowed Transfer pricing adjustment - comparability - Held that:- We find that the grievance of both the parties are against exclusion of the super profit making comparables and the low profit making comparables from the list of comparables adopted by the TPO. We find that the CIT(A) has not given any reasoning for such exclusion. As far as Infosys is concerned, we find that it satisfies the turnover filter, as its turnover is 6,850 crores as against the assessee’s turnover of 8.29 crores. So the said company is rightly excluded from the list of comparables. But however, as regards other comparables with both high margin and low margin companies, we are of the opinion that the CIT(A) ought to give reasoning before excluding the same. As the order of the CIT(A) is silent as regards the reason for their exclusion, we deem it fit and proper to remit the issue back to the file of the CIT(A) for reconsideration
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