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2024 (12) TMI 852 - AT - Income TaxStay application - TP adjustment - comparable selection - HELD THAT - We find merit in favour of the assessee on the basis of the fact that the comparables rejected or introduced seem to be making marginal impact in the margins. At the same time the assessee is a debt free company, therefore, the two disallowances on account of provision of software services and interest outstanding receivables appear to be quite arguable. As a consequence of above, the present stay application is allowed and demand for A.Y.2020-21 is stayed for a period of 180 days or till the disposal of the appeal which ever is earlier. An early hearing is also given for 19.09.2024. The registry is directed to list the appeal on 19.09.2024 and there shall be no separate notice of the date of hearing. Stay application is allowed.
The Appellate Tribunal ITAT Delhi allowed the stay application filed by the assessee for A.Y. 2020-21 due to marginal impact of comparables rejected or introduced by TPO on margins. The demand was stayed for 180 days or till appeal disposal. Early hearing scheduled for 19.09.2024 without separate notice.
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