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2022 (3) TMI 650 - AT - Income TaxRectification of mistake - CIT(A) completely rejecting the working capital adjustment while determining the arm's length price for the SWD services provided by the Assessee which was granted by the Ld. AO/ Ld. TPO even though on a restricted basis. - whether CIT(A) erred in disregarding the fact that working capital adjustment is an economic adjustment which would enhance the comparability analysis and ought to be carried out for the purposes of comparability analysis? - HELD THAT:- We have carefully gone through the log book maintained by us and find that there is no whisper about these grounds during the hearing of the appeal, as such the Tribunal recorded a finding in para 29 of its order that no other grounds were pressed in the TP matters, other than what is adjudicated by the Tribunal in its order. Being so, we do not find any infirmity in the order of the Tribunal on this issue. Accordingly, the MP filed by the assessee is dismissed. Comparability of KALS Information Systems Ltd - The Tribunal committed an error in giving finding in para 43 of its order. Accordingly, para 43 of the order of the Tribunal dated 24.11.2021 is modified and substituted to read as follows:- “43. Accordingly, this comparable to be excluded in the list of comparables.” Except the above, there is no change in the order of the Tribunal dated 24.11.2021.
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