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2020 (5) TMI 731 - AT - Income TaxTP Adjustment - comparable selection - RPT filter @ 25% - HELD THAT:- We are of the considered opinion that this matter requires verification at the level of TPO for determination of the inclusion and/or exclusion of this comparable on the basis of RPT filter as adopted by the assessee and the TPO. We, therefore, deem it proper to restore this issue to the file of the AO/TPO for deciding this issue afresh after verification of the RPT from the financials already furnished by the assessee. Ground of appeal No.1 is accordingly allowed for statistical purposes. Adjustment on account of difference of working capital employed by the assessee company and the comparables - HELD THAT:- Both the sides agreed that this issue needs to go back to the file of AO/TPO for correct determination of computation of working capital adjustment. We, therefore, deem it proper to restore the issue to the file of AO/TPO for determination of the working capital adjustment. Ground No.3 of the assesseee is accordingly allowed for statistical purposes. Inclusion/exclusion of certain comparables - Companies functionally dissimilar with that of assessee or any extraordinary events on account of amalgamation need to be deselected from final list.
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