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Per N.V. Vasudevan, Vice President
The cross appeals by the assessee in IT(TP)A No.52/Bang/2016 and by the revenue in IT(TP) A No.97/Bang/2016 was disposed of by a common order of this Tribunal on 05.08.2020.
In adjudication of the assessee’s appeal in IT(TP)A No.52/Bang/2016, at page 9 of the order of the Tribunal in para 18, ground No.17 relating to corporate tax issue is referred to and reproduced as follows:- “17. The learned AO / learned TPO erred in ignoring the limited risk nature of the contractual services provided by the Appellant and in not providing an appropriate adjustment towards the risk differential, even when full-fledged entrepreneurial companies are selected as comparable companies.”
It is noticed that the ground of appeal No.17 reproduced as above in the order of Tribunal is in fact ground No.16 raised by the assessee and IT(TP)A Nos.52 & 97/Bang/2016 Page 2 of 2 erroneously reproduced as ground No.17 in the order. Therefore, the ground of appeal
No.17 reproduced at para 18 of the order of Tribunal is substituted to read as under:- “17. The learned AO has erred in granting credit for advance taxes paid by the Company only to the extent of Rs.113,641,369 instead of Rs.115,000,000.”
4. Thus, the order of the Tribunal dated 05.08.2020 stands modified to the extent indicated above.