Tuesday, 8 April 2014

TP adjustment set aside as comparable of TPO was functionally different and had an odd event of amal

IT/ILT : Where in course of transfer pricing proceedings, TPO made certain addition to assessee's ALP in respect of its business of software development services, in view of fact that in case of one comparable selected by TPO, an extraordinary event of amalgamation took place whereas some other comparables were improper on account of functional difference, impugned adjustment was to be set aside and, matter was to be remanded back for disposal afresh


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