Monday, 26 May 2014

Bad debts not arising from transactions with AEs couldn’t be taken as part of operating cost for com

IT/ILT: Where in transfer pricing proceedings TPO made certain addition to assessee's ALP in respect of services rendered in ITES sector, in view of fact that TPO had not properly allocated segmental expenditure as bad debts not related to AE transactions were wrongly considered as part of operating cost for determining ALP of transactions with AE and, moreover some comparables selected were improper on account of functional difference, high turnover etc., impugned adjustment was to be set aside


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