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2020 (10) TMI 1369 - ITAT DELHITP adjustment - MAM - why CUP method cannot be applied as the most appropriate method? - HELD THAT:- Since the facts of the instant case are identical to the facts for the A.Y. 2011- 12 and AY 2013-14, therefore, respectfully following the decision of the Tribunal in assessee's own case and in absence of any distinguishable features brought to our notice, we are of the opinion that CUP is the most appropriate method in the instant case which has been applied by the assessee for benchmarking the transactions for provision of consultancy services rendered. We hold and direct accordingly. Since this issue is decided in favour of the assessee. Non-grant of mat credit under section 115JAA and short grant of tax deducted at source - As we deem it proper to restore this issue to the file of the AO with a direction to verify the record and give proper credit in respect of the same. Needless to say, AO shall give due opportunity of being heard to the assessee and decide the issue as per fact and law. We hold and direct accordingly. Grounds raised by the assessee are allowed for statistical purposes.
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