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2022 (12) TMI 833 - AT - Income TaxTP adjsutment - “AE” investment banking activities - comparable selection - comparable were selected by the TPO on basis of business activities KPO which is summarily rejected by the ld. CIT(A) - HELD THAT:- Rejection of KJMC Global Market (India Limited and Kinetic Trust Limited - The persistence loss- making company are normally excluded as comparable. As per the submission of assessee both the companies are made profit in relevant years. DR did not strongly object on the plea of assessee. No objection was made by the ld DR in factual position. So, these companies should not be excluded on the ground of loss-making company. It is to be directed to the ld. TPO that KJMC Global Market (India) Limited and Kinetic Trust Limited be included in the set of comparable. Accordingly, the Ground no-1 of the assessee is allowed. Erroneous acceptance of Khandwala Securities Ltd and Keynote Corporate Services Ltd. - As submitted that the principle that companies making abnormally high profit margin are required to be excluded - DR did not make any strong objection in this issue. No contrary judgment was produced by ld DR during hearing. We are directing that M/s Khandwala Securities Ltd & M/s Keynote Corporate Services Ltd be excluded from the set of comparable. Accordingly, the Ground no-2 of the assessee is allowed.
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