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2019 (10) TMI 1581 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Companies rejected as functionally dissimilar with that of assessee providing marketing support services. Addition on account of unbilled revenue written off and security written off - as per AO assessee could not explain properly as to whether the amount actually booked as revenue from M/s Rolls Royce International Ltd. during F.Y. 2011-12 includes the sum booked as unbilled revenue during F.Y. 2010-11 - HELD THAT:- As it is the submission of assessee that due to certain small arithmetical error there is some minor difference in the figures shown in 2012-13. however, it is his submission that given an opportunity, the assessee is in a position to reconcile the same before the A.O/TPO that these are mere contra entries and no addition is called for - we deem it proper to restore the issue to the file of the A.O./TPO with a direction to grant one more opportunity to the assessee to substantiate its case - grounds raised by the assessee are accordingly allowed for statistical purposes.
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