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2018 (11) TMI 435 - AT - Income TaxTPA - Comparable selection - Held that:- The appellant company is engaged in the business of I.T. Enables Services [ITES]. In our considered opinion, the appellant company itself is providing services in civil and structural, in accordance with the requirement of its AE, mainly related to construction activities. In our considered opinion, the functional profile of the appellant is not different from the functional profile of Mahindra Consulting Engineers Limited. We do not find any merit in the contention of the ld. AR. This comparable has been rightly used by the TPO and, therefore, no interference is called for. Companies functionally dissimilar with that of assessee need to be deselected from final list. A perusal of the directions of the DRP show that the DRP has directed to treat the gain/loss on account of forex fluctuation as non operating in nature but while following the directions of the DRP, the Assessing Officer has not disclosed the computation of revised adjustment in this regard. We, accordingly, direct the Assessing Officer to compute the revised adjustment as per directions of the DRP
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