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2022 (2) TMI 1281 - AT - Income Tax
TP Adjustment - Comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee engaged in providing broad range of software development, maintenance & support services and Information Technology Enabled Services to its Associated Enterprises need to be deselected.
Working capital adjustment - We allow the working adjustment done by the assessee.
Provision for bad and doubtful debts and bad debts as a non-operating expenditure - We remit this issue to the file of the AO with a direction decide the same in line with the order of ITAT for AY 2014-15 [2021 (1) TMI 25 - ITAT HYDERABAD] Thus, this ground is allowed for statistical purposes.
Non granting credit of DDT paid by the assessee on the dividends distributed to the shareholders - We remit these issues back to the file of AO with a direction to consider the evidences filed by the assessee and decide the issues in accordance with law after providing opportunity of being heard to the assessee. The assessee is directed to substantiate its claim by way of documentary evidence before the AO.