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2016 (6) TMI 249 - AT - Income TaxTransfer pricing adjustment - turnover filter application - Held that:- CIT(A) directed the TPO to adopt the turnover filter of ₹ 1 crore to ₹ 100 crores. Further, the submission of the Ld. Counsel for the assessee that in the subsequent year the turnover filter criteria of ₹ 1 crore to ₹ 100 crores shown by the assessee has been accepted by the TPO and the DRP could not be controverted by the Ld. Departmental Representative. Further, we do not find any merit in the grounds raised by the revenue regarding certain observations of the CIT(A). Under these circumstances, we do not find any infirmity in the order of the CIT(A) on this issue - Decided against revenue Working capital adjustment - Held that:- Since the CIT(A) has directed the AO to grant working capital adjustment to the assessee on the basis of average credit/debit period for the year and commercial rate of interest and since working capital adjustment has been allowed to the assessee by the TPO in A.Y. 2009-10 and 2010-11, therefore, we do not find any infirmity in the order of the CIT(A) directing the TPO to grant working capital adjustment on the basis of certain calculation - Decided against revenue
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