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2022 (12) TMI 330 - ITAT DELHITP Adjustment - comparable selection - MAM - Revenue submitted that since there is only one comparable remaining and hence only one price the tolerance range of ± 5% is not applicable as it is applicable only when there are more than one price and an arithmetic mean has been arrived at - HELD THAT:- The first proviso itself envisages that there can be only one price determined by most appropriate method. The second proviso mentions about application of tolerance range to the arm’s length price so determined. So the reference to ‘so determined’ is with regard to first proviso and as already explained by first proviso contemplates that there can be only one price or more than one price. Hence, the objection of the ld. DR is rejected. Accordingly, we remit the issue to the file of AO to reject the two comparables already found uncomparable by ITAT in assessee’s own case and thereafter make the computation as per law as discussed by us hereinabove. Disallowance of bad debt - Taxpayer’s claim of bad debt was disallowed with respect to related entities on the ground that sufficient proof of their becoming bad has not been established - HELD THAT:- We find that the law in this regard has already been settled in the case of TRF Ltd [2010 (2) TMI 211 - SUPREME COURT]. The AO is directed to follow the same.
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