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2018 (4) TMI 1479 - HC - Income TaxALP determination u/s 92CA - selection / exclusion of comparable - functional dissimilarity - assessee objected to the inclusion of that concern on the ground that it reported high profits - Held that:- no segmental data with respect to the disparage income schemes of Brescon Corporate Advisors Ltd. was available. - the exclusion of Brescon Corporate Advisors Ltd. does not per se result in any error of law. In case of another company, the ITAT took note of the fact that the profitability of M/s Keynote Corporate Services arose unusual to 185% from the reported level of 94%. - ITAT noted that, There is no estoppel against the assessee from demonstrating that a particular comparable was wrongly included in earlier year and, therefore, it should be excluded in this year. - the findings of the ITAT cannot be faulted.
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