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2023 (4) TMI 617 - AT - Income TaxTP Adjustment - Adjustment on AMP expenses - HELD THAT:- When the TPO has not rejected the gross margin and the net margin of the assessee in the trading segment, separate TP adjustment on AMP expenses is not called for. Therefore, we delete the TP adjustment proposed by the TPO under the AMP segment. TP adjustment on BSS Segment - Comparable selection - Majestic Research Services & Solutions Limited Company is functionally not compatible with that of the Assessee as the company is engaged in the business of providing marketing research services and offers wide range of qualitative and quantitative research services. Scarecrow Communications Limited - Since the Tribunal has excluded this company as comparable for assessment year 2016-2017 and the profile is same for the relevant assessment year, namely, A.Y. 2017-2018, which has been even accepted by the TPO, the above company needs to be excluded from the comparable list. Pressman Advertising Limited - We find that the assessee’s main stream of revenue is for providing services pertaining to advertisement on radio, television and public relation. The same prima facie cannot be compared with the profile of the assessee’s business support services. Since the matter needs fresh examination, we restore the issue to the AO / TPO to consider whether Pressman Advertising Limited’s profile is the same as that of the assessee.
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