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2011 (3) TMI 269 - AT - Income TaxArms length price - Addition - Dispute resolution panel (DRP) - Non speaking order - Rule 10B of the Income-tax Rules, 1962 - DRP, has again, not gone into the objections raised by the assessee and it was only observed that the TPO made the rejection on a detailed FAR analysis, by undertaking a search of comparable companies and taking two companies which were used as comparable in the immediately preceding year - The TPO rejected the comparable companies used by the assessee based on a detailed FAR analysis as mentioned in the order - The record shows that the assessee had filed before the DRP, along with its objection, the facts as submitted to the Assessing Officer concerning the TP adjustment and the corporate tax disallowance, factual and legal arguments against the addition proposed by the Assessing Officer concerning the TP adjustment and the corporate tax disallowance and the case laws relied on by the assessee concerning the TP adjustment as well as the corporate tax disallowance - Appeal is allowed by way of remand
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