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2016 (5) TMI 1412 - AT - Income TaxTPA - selection of comparable - Held that:- Assessee company characterized itself as a provider of software and development services to its Associated Enterprises (AEs) and selected TNMM as the most appropriate method, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Apportioning certain expenses that are specifically incurred in respect of the non-STP units to the STP units of the assessee and thereby reducing the deduction available to the said STP units - Held that:- We are of the considered view that the AO has correctly made the apportionment between STP and STP units and as such, there is no scope in interfering the findings returned by the AO/DRP. Hence, ground determined against assessee.
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