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2021 (2) TMI 353 - ITAT MUMBAITP Adjustment - applicability of TNMM at entity level for computing the margin - assessee has raised objections against the comparables selected by the TPO - HELD THAT:- As decided in own case [2013 (8) TMI 735 - ITAT MUMBAI] [2013 (8) TMI 735 - ITAT MUMBAI] Considering the various discrepancies as well as infirmities in the approach adopted by both the parties we consider it appropriate that a fresh transfer pricing study be undertaken for selecting proper comparables after careful study of functional profile of the assessee so as to arrive at proper TP adjustment. There is no difference in the factual position in the impugned assessment year. Therefore, respectfully following the aforesaid decision of the co-ordinate bench, we restore the issue to the Assessing Officer for fresh adjudication keeping in view the observations of the co-ordinate bench reproduced hereinabove. Appeal filed by the assessee is allowed, for statistical purpose.
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