Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2017 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2017 (2) TMI 1337 - AT - Income TaxDetermination of arm’s length (ALT) of an International Transaction - comparable selection criteria - Held that:- Assessee is engaged in the business of software development and it provides software development services to its various group companies, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Adjustment towards working capital and risk adjustment - Held that:- Similar adjustments should also be allowed in the present assessment year. We hold and direct accordingly. We also observe that the principle reasons assigned by the DRP in the present assessment year was lack of details furnished by the assessee. In this regard we find that all the details have been given by the assessee in its transfer pricing study and we find that the observations of the DRP in this regard cannot be sustained. We accordingly direct that adjustment of 2% towards working capital adjustment and risk adjustment should be allowed to the assessee as was done in A.Y.2004-05. We hold and direct accordingly.
|