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2014 (1) TMI 852 - AT - Income TaxALP - Selection of comparables - Computation of difference in PLI (Profit Level Indicator) – Held that:- It is very clear from the computation of the assessee that the provision for outstanding derivative contracts was already added back in computing the total income of the assessee – Thus, the further addition made by the Assessing Officer has resulted in duplication - the addition of Rs. 60 lakhs is to be deleted. Non consideration of extra-ordinary items – Held that:- The TPO ought to have considered the extra-ordinary items while finalizing the Arm's Length Price (ALP) computation - proper weightage has to be given for all these extra-ordinary items explained by the assessee before the TPO - there will be no operating profit available for making ALP adjustment when the extra-ordinary items are given due treatment - nothing will be remained to make any addition by way of ALP adjustment - the order for entire ALP adjustment made by the assessing authority set aside – Decided in favour of Assessee.
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