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2016 (5) TMI 1375 - AT - Income TaxTPA - comparability - Held that:- Assessee was characterized as a routine service provider exposed to less than normal risk associated with its business. Based on this assessee was selected as a tested party and transaction net marginal method was considered as the most appropriate method, thus companies functianlly dissimilar with that of assessee need to be deleted and we direct exclusion of the above two comparables namely TSR Darashaw Ltd. and HCCA Business Services Pvt. Ltd. Disallowance u/s 14A - Held that:- It is undisputed fact that during the year assessee has not received any dividend and therefore, no disallowance can be made in the hands of the assessee u/s 14A of the Income Tax Act in absence of any exempt income. See Cheminvest Vs. CIT [2015 (9) TMI 238 - DELHI HIGH COURT] . Thus disallowance deleted - Decided in favour of assessee.
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