Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2019 (11) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2019 (11) TMI 1094 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- Companies functionally dissimilar with that of assessee provides who Engineering services (including preparation of engineering packages, equipment designs, etc.) and Technical assistance services (including providing engineers for supervision) to HTAS for their global projects (including projects in India) need to be deselected from final list. Adjustment in the margin due to different risk profile of the comparable companies - HELD THAT:- AR as well as Ld. DR for the revenue brought to notice of the Bench that in AY 2009-10 and 2010-11, this issue has been restored back to the TPO/AO by the Tribunal vide order [2017 (5) TMI 1648 - ITAT DELHI] AND [2018 (12) TMI 1563 - ITAT DELHI] . We are of the considered view that identical issue of this year is also required to be remanded back to the TPO/AO to decide afresh after providing an opportunity of being heard to the assessee.
|