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2015 (7) TMI 438 - AT - Income TaxTransfer pricing adjustment - selection of comparables - Held that:- When both parties agree that the company M/s LAN ESADA Industries Ltd. is a comparable, then the correct financial data of that company as reflected by its annual report, which were not available before the TPO, has been rightly considered by the ld. CIT(A). We also do not find any merit in the submission of the ld. DR that pro rata data should not be taken. Comparables M/s Kushagra Software Limited to be excluded - Decided in favour of assesse. Bad debts - whether are extraordinary items and cannot be considered as operational cost and hence, they should have been removed before arriving at operational margins? - Held that:- While arriving at operational profit ratio, extraordinary items should be eliminated. Bad debts or provision for bad debts are extraordinary items and have to be eliminated for arriving at the operational profit. - Decided in favour of assesse.
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