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2021 (7) TMI 1301 - AT - Income TaxTP adjustment - comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected. Value of domestic transaction for making adjustment instead of restricting the adjustment to the international transaction - Statutory provisions under chapter X of the Act mandates ALP to be determined only in respect of transactions with associated enterprises. Any adjustment which is in close of domestic transactions is uncalled for under this chapter. We accordingly direct the Ld. AO/TPO to restrict the adjustment if any that may be computed are wildly or giving effect to the order only in respect of the transactions that assessee had with its associated enterprises. Accordingly this ground raised by assessee stands allowed for statistical purposes. Depreciation disallowed on computer peripherals at 60% - As AR submitted that DRP had directed the Ld.AO to grant depreciation at 60% on computer peripherals which has not been followed while passing the final assessment order. We thus direct the Ld. AO to comply with the directions of DRP in accordance with law.
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