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2018 (5) TMI 2122 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- As noticed that the ITAT Delhi Bench ‘I’, New Delhi in the case of M/s Mercer Consulting (India) (P.) Ltd. [2014 (7) TMI 715 - ITAT DELHI] directed to exclude the Coral Hub Ltd. Also we direct the AP/TPO to exclude M/s Coral Hub Ltd., Cosmic Global and eClerx Services from the list of the comparable while determining the OP/OC for the purposes of arm’s length price. Computation of operating profit margins of the comparables - HELD THAT:- We deem it appropriate to remand this issue back to the file of the AO/TPO to be adjudicated after considering the submissions and the relevant material furnished by the assessee. Disallowance u/s 14A of the Act r.w. Rule 8D - As submitted no investment was made by the assessee for the year under consideration and this vital fact was not considered by the TPO/AO while making the disallowance u/s 14A - HELD THAT:- We are of the view that this issue also requires verification/adjudication at the level of the TPO/AO. Accordingly, this issue is also restored back to the file of the AO/TPO to be adjudicated in accordance with law after providing due and reasonable opportunity of being heard to the assessee.
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