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2019 (10) TMI 192 - AT - Income Tax
TP Adjustment - Comparable selection - HELD THAT:- As per present position of law, RPT filter should be applied is at 15%. We therefore set aside order of Ld.AO/TPO and restore back the issue to file of Ld.AO/TPO for fresh decision by applying RPT filter of 15%
Companies functionally dissimilar with that of assessee's ITES segment and with a difference risk profile or any extraordinary event like amalgamation seeked need to be deselected from final list.