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2021 (2) TMI 1325 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee carries on IT enabled services[ITes] in the form of research activities according to the terms of its agreement with its AE which is driven by business information, market research and intellectual property research, thus companies functionally dissimilar with that of assessee need to be deselected. Working capital adjustment - CIT-A directed AO/TPO to grant working capital adjustment based on the OECD formula and by taking the PLR as adopted by the Slate Bank of India in FY 2008-09 for working capital loans - HELD THAT:- We are of the considered opinion that no interference is required and while upholding the same, we reject the challenge of the Revenue on this aspect.
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