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2016 (6) TMI 1296 - AT - Income TaxTransfer pricing addition - comparable selection criteria - functional similarity - Held that:- The assessee as ITES provided by the assessee to its Associated Enterprises (AEs) have operating profit cost at 14.36%.thus companies functionally dissimilar with that of assessee need to be deselected from final list. Section 10A deduction - Held that:- As relying on case of Wipro Ltd. case [2015 (10) TMI 826 - KARNATAKA HIGH COURT] we direct the Assessing Officer to allow claim of deduction under Section 10A without setting off brought forward losses and unabsorbed depreciation.
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