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2018 (1) TMI 1318 - AT - Income TaxTPO - comparable selection criteria - functional similarity - Held that:- The assessee was engaged in providing software development services, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Adjustment on account of working capital - Held that:- As the assessee pointed out that in all the earlier years, working capital adjustment was allowed to the assessee. However, it was denied during the year. He fairly agreed that the issue may be sent back to the file of Assessing Officer and the actual may be computed. We find merit in the plea of assessee in this regard, where similar issue of working capital adjustment has been allowed in the hands of assessee and there is no finding of TPO why the same is being denied during the year under consideration - we remit this issue back to the file of Assessing Officer, who shall afford reasonable opportunity of hearing to the assessee and allow the working capital adjustment as per law
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