Reassessment under s.148A held valid; s.69 additions totaling Rs.7,00,000 deleted after acceptable contemporaneous explanations for property investmen...
Adjudication set aside; Rule 9 valuation based on internet engineer report quashed for Rule 3(4) non-compliance; Section 138B cross-examination requir...
ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin.
ITAT allowed Ground No.2, holding that Company A is not a comparable for TP adjustment. The Tribunal accepted that Company A admitted to ROC it is exclusively a manufacturer, whereas the assessee conducts both manufacturing and trading; the TPO's 75% trading-turnover filter consequently excluded Company A. On this basis the AO/TPO is directed to delete Company A from the selected comparable set. The parties conceded that Company B's operating margin is 2.92%; accordingly the AO/TPO is directed to re-compute the comparable average and TP result incorporating Company B at a 2.92% margin.
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