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2017 (12) TMI 406 - AT - Income TaxTPA - international transaction - Held that:- Since the finding of the Hon'ble High Court for Assessment Year 2005-06 has clearly concluded that for Assessment Year 2007-08 the assessee has not carried out any research and development activity, the same cannot be taken into account for rendering services as per international transactions. Thus, the assessee company has not carried out any international transaction. As related to working capital adjustment the Hon'ble High Court decision was not available before the TPO as well as before the DRP. Therefore, the same should be verified by the TPO/A.O. Needless to say, that the assessee be given full opportunity of hearing.
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