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2020 (4) TMI 746 - AT - Income TaxTP Adjustment - filters application - HELD THAT:- As observed that authorities below have cherry picked on using filters without understanding business model of assessee. It is observed that DRP applied on-site revenue filter suo moto, without being considered by TPO. We are of the opinion that transfer pricing adjustment made by AO/TPO needs to be re-looked in accordance with law. As observed that AO while passing final assessment order in computation of assessed income has not considered transfer pricing adjustment that has been made in para 3 of assessment order. This shows a sheer negligence on behalf of Ld. AO and non-application of mind. Provision for warranty disallowed - HELD THAT:- We direct Ld. AO to verify the claim of assessee in the light of decision by Hon’ble Supreme Court in case of Rotork Controls India (P) Ltd., vs CIT [2009 (5) TMI 16 - SUPREME COURT] and Hon’ble Delhi High Court in case of CIT vs Goetz India Ltd., [2010 (1) TMI 29 - DELHI HIGH COURT]
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