Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2022 (8) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2022 (8) TMI 1285 - AT - Income TaxTP adjustment in relation to software development services - comparable Companies selection - HELD THAT:- As we hold that companies having turnover in excess of Rs.200 crores should be excluded from the list of comparables. We direct the AO/TPO to recompute the ALP. Working capital adjustment - Respectfully following the above decision of the Tribunal in the case of Huawei Technologies India (P) Ltd.[2021 (8) TMI 1334 - ITAT BANGALORE] we direct the AO to allow the working capital adjustment and re-compute the ALP accordingly. Notional interest on outstanding receivables - AO computed the notional interest on delayed receivables at 4.98% on the ground that the assessee has failed to furnish the details of invoice-wise receipt and arrived at an adjustment - HELD THAT:- As it is clear that the assessee has realized payments against all the invoices within a period of 30 days as agreed between the assessee and the AE. We are therefore of the considered view that there is no delay in receipt of payment warranting levy of ay notional interest. We therefore delete the adjustment made in this regard. Partial denial of claim of depreciation on goodwill - Goodwill arising on slump sale - eligible for depreciation - difference between the purchase consideration and net assets taken over - HELD THAT:- As relying on M/S. I&B SEEDS PRIVATE LIMITED [2022 (6) TMI 1295 - ITAT BANGALORE] hold that depreciation on goodwill is an allowable claim u/s. 32(1) of the Act. This ground is allowed in favour of the assessee.
|