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2016 (7) TMI 238 - AT - Income TaxComputation of adjustment in respect of provision of services to AEs at entity level - Held that:- Addition is to be confined to the component of international transactions with the AEs alone and not to the entire segmental results. The adjustment arising as a result of TP analysis is to be confined to the international transactions undertaken with the AEs alone and not in relation to non AE transactions. Sundry credit balances written back - Held that:- It is not in dispute that no details were filed either before the AO or before the DRP. However, since it involves computation of operating profit of the assessee and since the assessee has filed certain details which were not before the TPO or the DRP, therefore, we, in the interest of justice, restore this issue to the file of the AO/TPO with a direction to give an opportunity to the assessee to justify and explain to the satisfaction of the AO/TPO that the sundry credit balances written back amounting to ₹ 29,33,688/- is part of the operating income of the assessee. The AO shall decide the issue in accordance with law after giving due opportunity of being heard to the assessee. We hold and direct accordingly. This ground by the assessee is accordingly allowed for statistical purposes. Computing the deduction u/s.10A - Held that:- We restore this issue to the file of the AO with a direction to compute the deduction u/s.10A as per law after giving due opportunity of being heard to the assessee.
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