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2012 (10) TMI 897 - AT - Income TaxTransfer pricing - ALP - Disallowance of expenses - reduction in net profit ratio - alleged that turnover is decreased in comparison to last year but expenses increased significantly as compared to previous year figure – Held that:- Income of the assessee has been accepted by the learned TPO as being on arm's length basis - Assessing Officer has made the addition merely on estimates - Assessing Officer has first time confronted the assessee on 2nd of December, 2008. It was supposed to file reply by 10.12.2008. The assessee has filed the reply on 12.12.2008. Again the Assessing Officer raised the query on 24.12.2008 and directed the assessee to explain by 26.12.2008. In this short period, assessee could not submit the reply and the Assessing Officer accordingly passed the assessment order before 31.12.2012 - sufficient opportunity was not granted to the assessee by the Assessing Officer. He has just provided two days time for explaining its position – matter remanded to Assessing Officer for readjudication
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