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2019 (2) TMI 1754 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- Referring to International transactions of the software development services segment of the assessee companies functionally dissimilar with that of assessee need to be deselected. Internet access charges - AO disallowed the expenses claimed by invoking the provisions of section 40(a)(ia) - HELD THAT:- Respectfully following the decision of the Co-ordinate Bench of this Tribunal in the assessee’s own case for Assessment Year 2009-10 [2013 (12) TMI 1419 - KARNATAKA HIGH COURT] , we decide this issue in favour of the assessee.
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