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2016 (6) TMI 1350 - HC - Income TaxTP adjustment - selection of comparable - functinal similarity - inclusion of 'SIRO Clinpharm Pvt. Limited' as a comparable - Tribunal while upholding the inclusion of 'SIRO Clinpharm Pvt. Limited' as a comparable, was justified in directing the Assessing Officer to make certain adjustment on account of different business model adopted by the said comparable - HELD THAT:- We are unable to understand how the Revenue could have any grievance to the impugned order of the Tribunal on the above account. Further, we find that the impugned order has relied upon the decision of the Tribunal in ITO Vs. M/s. Zydus Altana Healthcare Pvt. Ltd. [2010 (4) TMI 883 - ITAT MUMBAI] wherein on similar facts the Tribunal had restored the issue to the Assessing Officer to make suitable adjustment in view of M/s. Siro Clinpharm Pvt. Ltd. who conduct clinical trials on its own. No substantial question of law. Depreciation on the assets of the assessee's Ankleshwar plant - the said assets had not been used by the assessee company - HELD THAT:- It is agreed position between the parties that the issue stands concluded against the Revenue in respect of same respondent – assessee relating to assessment year 2001-02. No substantial question of law.
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