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2015 (1) TMI 6 - AT - Income TaxTransfer pricing adjustment Selection of comaprables - Assessee into the business of rendering technical help desk for end users Held that:- Assessee has rightly submitted that if the above four entities are excluded from the final list of comparables for the purpose of comparability analysis, the Arithmetic Mean Margin of the remaining eight comparables would come to around 17% and the same being lower than the profit margin charged by the assessee company to its AE in the relevant international transactions, no addition on account of TP adjustment is required to be made in the case of the assessee the AO/TPO is directed to verify the claim of the assessee by re-computing the Arms Length Price of the international transactions of the assessee company with its AE after excluding the four entities form the list of final comparables Decided in favour of assessee. Computation of deduction u/s 10A - Mistake in taking the amount of book profits or not Held that:- The assessee has only sought a direction from the Tribunal to the AO to verify the relevant mistake from the record and rectify the same - Since the revenue has no objection in this regard, the AO is directed to verify from the record the mistake pointed out by the assessee Decided in favour of assessee.
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