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2018 (9) TMI 1020 - AT - Income TaxTPA - Comparable selection criteria - Held that:- Assessee which is a captive entity is engaged in providing data processing and back office support services including payment processing, data processing, documentation processing, investigation related services and trade central processing services to its AEs thus companies functionally dissimilar with that of assessee need to be selected from assessee. Risk adjustment - Held that:- Now when the assessee in the case before us had claimed adjustment of 10.29% on account of difference in the risk profile before the TPO and DRP, thus in all fairness, respectfully following the view taken by the Tribunal in the assesses own case for A.Y 2005-06, therein restore the matter to the file of the TPO, in the same terms, for deciding the said issue afresh after considering the decisions relied upon by the assessee.
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