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Section 92C4 Section 143(2)3 Section 143(3)2 Section 142(1)2 Comparables/TP2

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

In the result, appeal filed by the assessee is partly allowed

ITA 152/VIZ/2021[2016-17]Status: DisposedITAT Visakhapatnam23 Jan 2023AY 2016-17

Bench: Shri Duvvuru Rl Reddy, Hon’Ble & Shri S Balakrishnan, Hon’Ble

For Appellant: Sri Darpan Kirpalani CAFor Respondent: Sri MN Murthy Naik, CIT-DR

Section 10ASection 142(1)Section 143(2)Section 143(3)Section 36(1)(va)Section 92C

transfer pricing adjustments not on proportionate basis which was consistently followed in earlier assessment years. 4.12. Not providing appropriate economic adjustments towards material differences between the operational profile of comparable companies and the appellant with respect to working capital adjustments. Grounds for disallowance of technical support services fees paid. 5. On the facts and in the circumstances of the case

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. ASSISTANT COMMISSIONER OF INCOME TAX, DC/AC 4(1), VISAKHAPATNAM

TEEJAY INDIA PRIVATE LIMITED,VISAKHAPATNAM vs. THE ASSISTANT COMMISSIONER OF INCOME TAX, CIRCLE - 5(1), VISAKHAPATNAM