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2019 (11) TMI 1411 - AT - Income TaxTP Adjustment - comparable selection - functional similarity - HELD THAT:- Assessee is engaged in the business of manufacturing of and trading in air intake systems and filters for automotive and heavy engineering industry and rendered services to its Associated Enterprises (AEs) in the nature of services using CAD and computer aided manufacturing software tools thus companies functionally dissimilar with that of assessee need to be deselected from final list. Working capital adjustment - HELD THAT:- Authorised Representative are realistic as the TPO has not given proper basis/findings in restricting the Working Capital Adjustment to 1.63% and we support our view on judicial decisions and restored this disputed issue to the file of TPO for computing adjustment of working capital on actual facts and allow the grounds of appeal of the assessee for statistical purposes.
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