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2012 (12) TMI 278 - ITAT, HYDERABADDeduction u/s 80IA – alleged that the company inflated the income of Dehradun unit by deflating the income of other units. He arrived at the income of Dehradun unit by working out the gross profits of all units separately and arriving at the average gross profit rate and applied it to Dehradun sales – Held that:- Proviso to section 80IA(8) of the Act clearly empowers the assessing officer to re compute the eligible profits on a reasonable basis as he deems fit - it is most appropriate to consider the actual cost as per cost records maintained by the assessee and thereafter assessing off ice consider the profits on these transaction as compared to other industries in similar line or if there is no comparable fix reasonable percentage of profit depending upon market condition prevailing in the similar line of industry – matter remanded to AO
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