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2017 (9) TMI 1024 - AT - Income TaxTPA - comparable selection - Held that:- Assessee is primarily engaged in providing technical support to its associated enterprises (AEs). The technical support services provided by the assessee to its AEs relate to provision of erection, installation, commissioning, warranty administration, operation and maintenance, inspection, renovation and modernization services for power plants and turbines, this companies functionally dissimilar with that of assesse need to be deselected from final list. Tax deductible at source raised by the DRP and the consequential disallowance u/s 40(a)(i) - AR submits that while computing the disallowance u/s 40(a)(i) of the Act the AO should have considered the factual situation that has a bearing on the computation of disallowance u/s 40(a)(i) - Held that:- From a reading of the assessment order, we find that the AO did not consider any further facts while complying with the directions of the DRP, as such, this fact needs verification at the end of the AO, after affording an opportunity to the assessee to furnish the requisite details that have a bearing on the disallowance u/s 40(a)(i) of the Act. We, therefore, set aside this aspect to the file of the AO.
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