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2019 (5) TMI 1741 - AT - Income TaxTP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee company is engaged in providing local logistics of freight forwarding services in India which includes cargo consultation services, international freight forwarding services, warehousing management services and other local logistic support services thus companies functionally dissimilar with that of assessee need to be deselected from final list. Government owned companies cannot be construed as a comparable. Chargeability of interest u/s. 234A - HELD THAT:- AR stated that due date of filing return of income for the A.Y.2010-11 was extended by CBDT to 15th October 2010 for which he placed on record the order passed by the CBDT on 27/09/2010. The return of income was filed by the assessee on 15/10/2010 i.e., on the due date. Hence, no interest u/s.234A of the Act could be levied on the assessee. Accordingly, the ground raised by the assessee is allowed.
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