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2016 (6) TMI 1332 - AT - Income TaxAddition u/s 80IA - yielding abnormal profits - excess profit on the ground that the assessee had not booked any expenses in respect of the technical know-how and goodwill - Held that:- The assessee was not able to show any change in the given facts in the instant year. CIT(Appeals), after discussing the issue in detail was of the opinion that availability of technical know-how, good will and customer base to the assessee free of cost has resulted in yielding abnormal profits to the assessee which stand in glaring contrast to the profits returned by his sister concern M/s Stoneage in the same line of business. CIT(Appeals) was, therefore, of the opinion that assessee certainly would have been under an obligation to pay suitable price for the technical know-how, good will and customer base, had he followed the arm’s length principles while dealing with M/s Stoneage Industrial. Therefore, ld. CIT(Appeals) correctly followed the decisions of earlier years while deciding the issue against the assessee. The finding of fact recorded by the authorities below in assessment year under appeal as well as in earlier years, have not been rebutted through any evidence or material on record. - decided against assessee.
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