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2014 (2) TMI 380 - AT - Income TaxTransfer Pricing Adjustment u/s 92CA(4) of the Act Various expenses incurred Disallowance u/s 14A of the Act - Cost of funds utilized Held that:- TPO has proceeded to draw an adverse inference against the assessee on the premise that JV agreement was not filed, whereas the assessee has demonstrated from the paper book that JV agreement was filed - The DRP has confirmed the action of assessing officer/TPO in this behalf without giving any finding. Disallowance u/s 14A the assessee's main claim has not been examined i.e. about the equity participation being a business decision and it was not investment to earn any exempt income thus, it will be desirable and in the interest of justice to set aside both the issues to the file of assessing officer to consider the same afresh after giving the assessee adequate opportunity of being heard Decided in favour of Assessee.
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