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2019 (4) TMI 1898 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- As relying on case of B.C. MANAGEMENT SERVICES PVT. LTD. [2017 (12) TMI 255 - DELHI HIGH COURT] exclude TCS E-Serve Ltd. from the final list of comparables. TP adjustment to the book profit as per section 115JB - HELD THAT:- As decided in the case of Owens Corning [India] Ltd [2016 (5) TMI 1098 - ITAT MUMBAI] as perusal of the assessment order that the AO has simply made addition to the amount of net profit as per profit and loss account for the purpose of computation of income u/s 115JB without even mentioning that under what provisions this addition was being made. Such an approach is highly unfair and brings undue and avoidable hardship to the tax payers and we recommend that such a casual approach should be avoided by the revenue officers, as it may tarnish image of the income tax department, which may in turn discourage voluntarily compliance by the taxpayers. Thus, we delete the addition made by the AO. - Decided in favour of assessee.
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