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2022 (12) TMI 923 - AT - Income TaxTP Adjustment - comparable selection - IT enabled services segment - HELD THAT:- Companies functionally dissimilar with that of assessee need to be deselected from final list. Mismatch of the income shown by the assessee and the entries shown in Form 26AS - HELD THAT:- The disagreement between the Assessing Officer and the assessee with respect to the income received by the assessee or vis-à-vis the amount shown in 26AS can only be resolved by making necessary enquiries from the persons who had deducted the TDS amount. The details of the persons i.e., Names, PAN numbers and addresses, are all available in form 26AS. Therefore, we deem it appropriate to restore the issue to the file of the Assessing Officer with the direction to verify once again the claim of the assessee by using powers conferred under the Act and find out whether the said income pertains to assessee company or not from the said persons who had allegedly deducted the tax as reflected in 26AS. This ground is allowed for statistical purposes.
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