2016 (9) TMI 196 - HC - Income Tax

Transfer pricing adjustment - selection of comparable - Held that - Direction to the Assessing Officer ( AO ) to include certain companies for consideration of the Transfer Pricing Officer ( TPO ) as a comparable while excluding certain other companies which were considered by the TPO stands covered by decision in assessee s own case for AYs 2004-05 and 2005-06. Adjustment for interest no receivables - Held that - The Court finds that the ITAT has returned a detailed finding of fact that the Assessee is a debt free company and the question of receiving any interest on receivables did not arise. Consequently, no substantial question of law arises for consideration as far as this issue is concerned.

Summary

The Delhi High Court allowed exemption in CM No.24523 of 2016. In ITA No. 379 of 2016, the Revenue raised two substantial issues against the ITAT's order for AY 2010-11. Question (A) was covered by a previous decision, and question (B) regarding interest on receivables was dismissed as the Assessee was a debt-free company. The appeal was ultimately dismissed.