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2022 (12) TMI 862 - AT - Income TaxTP Adjustment - segmental profitability consideration for benchmarking analysis - preparations of segmental accounting were not accepted by the DRP - HELD THAT:- The segmental accounting prepared cannot be rejected without pointing out defects in the allocation done by the assessee. Moreover, it is also noted that accounts are duly audited. There is also no rule that if segmental accounts are certified by CA. the AO should stop application of mind and follow it as a gospel truth. Hence, we are of the opinion that the segmental accounting prepared by assessee should be accepted and the consequence shall accordingly follow. Hence, to be fair to the parties, we are remitting the issue to the file of Assessing Officer once again to review the segment account prepared by the assessee and unless he can rebut the same with cogent reasoning, he shall accept the same. Assessee’s appeal is allowed for statistical purposes.
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