2015 (1) TMI 4

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....Verma, CIT, DR ORDER PER R.S. SYAL, AM: This appeal by the assessee is directed against the order passed by the AO on 27.02.2014 u/s 143(3) read with Section 144C and Section 254 of the Income-tax Act, 1961 (hereinafter also called 'the Act') in relation to the assessment year 2006-07. 2. Shorn of unnecessary details, it is noticed that the instant proceedings are second round pursuant....

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....tanding at 5.68%, the TPO proposed TP adjustment of Rs. 5,70,25,104/-. That is how the AO passed the impugned order. The ld. AR has brought to our notice that because of certain mistakes in the profit rates of the comparables, the assessee filed rectification application u/s 154 and the TPO reduced arithmetical mean of the profit rate of comparables to 18.71% as against the original 19.22%. A copy....

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....wing working capital adjustment on merits and simply rejected at the same at threshold by canvassing a view that the same is allowable only in manufacturing sector or trading sector etc. We are unable to accept the view taken by the authorities below. The Delhi Bench of the Tribunal in Mercer Consulting (India) Pvt. Ltd. vs. DCIT in ITA No.966/Del/2014 vide its order dated 6th June, 2014 has held ....