Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2020 (10) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (10) TMI 1210 - HC - Income TaxComputation of the ALP - Reason for selection by CASS (Computer Aided Search Selection) - approval of the PCIT for reference of the matter to the TPO - HELD THAT:- The petitioners’ submission to the effect that the reason for selection of scrutiny by CASS only involves a numerical reconciliation is, in our view an over simplification of the reason stated for selection. Perhaps the officer might have been more detailed in the choice of words employed so as to specifically refer to the issue of total employee cost. Non-reference to this is not fatal as the reason for selection by CASS has been produced and placed on record by the Officer while seeking approval of the PCIT for reference of the matter to the TPO. After the expiry of the interim protection by this Court on 29.03.2019 the Assessing Officer has issued a show cause notice dated 11.10.2019 in response to which the petitioner has replied on 23.10.2019 enclosing various details on the computation of the ALP as sought for by the Officer. The affidavit filed in support of the writ petition however, is silent in regard to these facts. The petitioner has thus not only cooperated and participated in the conduct of assessment but has also filed objections before the DRP that are pending disposal. WP disamissed.
|