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2018 (6) TMI 1454 - AT - Income TaxTPA - comparable selection - Held that:- Relying in assessee’s own case, we are of the considered opinion that there are no reasons brought to our notice to take a different view. We accordingly held that Hindustan Syringes & Medical Devices Pvt. Ltd. is not a suitable comparable. We, therefore, direct the learned TPO to exclude this company from the final list of the comparables. Risk adjustment - Held that:- Unless the adjustment on account of risk is quantified and working is given, it is not possible to direct the authorities below to allow the risk adjustment as pleaded by the assessee. It is not possible for us either to consider at the Tribunal level or to direct the AO to consider this aspect. Working adjustment - Held that:- Remand this ground to the file of the AO for computing the working capital adjustment only on the opening and closing balance of the working capital employed at the beginning and end of the year.
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