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2020 (12) TMI 1367 - AT - Income TaxTP Adjustment - adjustment has been made without properly appreciating the business model of the assessee - HELD THAT:- This issue was there in the appeal for the assessment year 2014- 2015, wherein the Tribunal in [2020 (2) TMI 1642 - ITAT BANGALORE] after examining the facts of the case, had accepted the contention of the assessee that the TPO conducted transfer pricing analysis on erroneous understanding of the business model of the assessee. Accordingly, the entire transfer pricing issue was set aside to the TPO with a direction that the transfer pricing analysis may be carried out having regard to the business model of the assessee - we restore the entire transfer pricing analysis for de novo consideration to the AO / TPO. Appeal filed by the assessee is allowed for statistical purposes
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