Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (2) TMI 810 - AT - Income TaxTP Adjustment - including the comparables i.e. M/s. Jain Granites & Projects India Ltd. and M/s. Somany Ceramics Ltd. for determining the adjustments made of Arm's Length Price under Section 92CA - HELD THAT:- We find that, by including the above two comparables raised in the grounds of Appeal, the Arm Length Price charges would change to 37.5% to 41%, which is still within the tolerance margin of ± 5% of the TP guidelines. We, by taking note of the concerns expressed by the ld. CIT, DR and make it clear that as a result of the dismissal of the Revenue's appeal on the ground of low tax effect, the said order would not act as a precedent where there is a tax effect in any subsequent or prior year where the Revenue would want to agitate the issues on similar grounds before the ITAT on merit. Accordingly, in the light of the submissions of the ld. AR and the DR, the appeal of the Revenue is dismissed.
|