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2020 (8) TMI 892 - AT - Income TaxTP Adjustment - comparability of a single comparable viz. Axis Integrated Systems Ltd. - HELD THAT:- In case of Arkay Logistics Ltd. [2019 (11) TMI 1075 - ITAT MUMBAI] the Tribunal, while examining the comparability of this very company has also found it to be functionally dissimilar to a routine marketing service provider. Though, the aforesaid decisions pertain to the assessment year 2013–14, however, the material facts on the basis of which such decisions have been rendered are no different from the facts involved in the impugned assessment year insofar as it relates to this comparable. We hold that Axis Integrated Systems Ltd. cannot be treated as a comparable to the assessee, hence, should be excluded from the list of comparables. Before us, the learned Counsel for the assessee has filed a written note, as per which, on exclusion of Axis Integrated Systems Ltd., the weighted average margin of rest of the comparables would work out to 15.36%. Assessee’s margin would be within the acceptable range requiring no further adjustment. We direct the Assessing Officer to compute the margin of comparables afresh and grant consequential relief to the assessee.
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