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2018 (4) TMI 32 - ITAT PUNETPA - comparables selection criteria - Held that:- Assessee was engaged in the business of software development and exports, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Economic adjustment on account of risk differences - Held that:- We direct the Assessing Officer to allow risk adjustment in turn relying on the proposition laid down by the Delhi Bench of Tribunal in the case of Sony India Pvt. Ltd. (2008 (9) TMI 420 - ITAT DELHI-H) wherein it was allowed @ 20%, and compute the TP adjustment, if any, in the hands of assessee. The ground of appeal Nos.3 to 8 are thus, allowed.
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