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2022 (1) TMI 647 - AT - Income TaxPenalty proceedings under section 271(1)(c) - TP Adjustment - comparable selection - HELD THAT:- We hold that the comparable doesn't pass the functional analysis and turnover filter and hence is liable to be excluded from the list of comparables We find that the reply of the assessee is only with regard to the adjudication of the ld. DRP on the comparables, hence doesn't amount to any admission or appraisal of new evidences before us. The assessee did not appear before the TPO but appeared before the ld. DRP. Before us, the order of the ld. DRP is being contested. Hence, the objections of the ld. DR as mentioned above is not pertaining to the order before the ld. DRP. We also were made aware that penalty proceedings for non-compliance have already been initiated by the revenue and hence the issue of non-compliance would be dealt separately based on the outcome of the penalty proceedings. Hence, the submission of the ld. AR is not relevant to the issue that is being adjudicated before us. Appeal of the assessee is allowed.
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