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2023 (4) TMI 223 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- We direct the AO/TPO to exclude the comparables on the basis of high turnover. Since the assessee’s turnover is only Rs.32.81 crores on the basis of turnover filter, selected comparables to be excluded. This ground of appeal is allowed. Order u/s 92CA(3) suffers from several computational errors which has led to incorrect computation of adjustment made in respect of the subject transaction - HELD THAT:- At the time of hearing, the Ld. A.R. submitted that there are various computational errors which lead to incorrect computation of ALP and this may be corrected. We acceded to the request of the Ld. A.R. Accordingly, any computational error committed by AO/TPO to be corrected. Accordingly, the issue remitted to AO/TPO to correct the mistake in computation of adjustments made in respect of international transactions while determining the ALP. Non-granting of working capital adjustment - HELD THAT:- We inclined to remit the issue to the file of AO/TPO to determine the correct working capital adjustment.
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