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2018 (6) TMI 495 - AT - Income TaxTPA - comparable selection - Whether turnover filter is to be applied or not - Held that:- turnover filter is one of the essential filter in order to select comparables when acted in same atmosphere - thus we do not find any error in the order of the ld.CIT(A) on adoption of turnover filter - hence grounds of appeal raised by the Revenue is rejected. Assessee is engaged in the business of manufacture of bulk drugs - Sales of Welcure Drug & Pharmaceuticals Ltd. are less than the turnover filter of ₹ 23 crores. Thus, it falls in the criteria of consideration and ought to be included in the list of comparable. Once it is included in the list of comparable, then the profit level indicator would be (-) 3.69% and no adjustment would be required in the value of international transaction as per section 92(3) of the Act, because it will go to reduce the value of the international transaction as declared by the assessee. Considering this aspect, we allow appeal of the assessee and delete adjustment made in the value of international transactions. Addition on account of inflation of purchase of raw-material- Held that:- To the show cause, assessee explained reasons for the variations in the consumption of the raw material as also extent of and how the variations arisen. As decided in assessee's own case [2015 (9) TMI 325 - ITAT AHMEDABAD] such addition to be deleted.
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