Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2018 (10) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2018 (10) TMI 70 - AT - Income TaxTPA - ALP determination - MAM Selection - comparable selection - Functional profile of company - Held that:- Functional profile of the assessee has remained unchanged from past year and the assessee continues to be a development centre undertaking contract R&D activities with insignificant risk as per Circular 6/2013. The above discussion brings us to an irresistible conclusion that the assessee is a contract R&D service provider, thus removal of companies from final list as functionally different and failed the service income filter along with diversified operations and non-availability of segmental data. Working capital adjustment - Held that:- We direct the A.O./TPO to allow working capital adjustment after due verification of the claim, whether it goes for or against it, and also recompute the assessee’s PLI from this international transaction by reducing operating expenses in relation to the earning of rental income from the overall operating expenses to be bifurcated amongst all the sources of the revenues of the assessee from operations including the instant international transaction.
|