Finding that the margins of assessee company fell within the tolerance limit of +/-5% for AY 2005-06, the Mumbai ITAT deleted the ALP adjustments proposed by the TPO in ITEs as well as IT segments. In that case, in ITES segment margin shown by the assessee and margin which has been determined falls within the tolerance limit of +/- 5% …
Relying on Co-ordinate bench ruling in assessee's own case for AY 2004-05 wherein assessee's additional evidences were admitted and matter was remanded back to TPO for fresh adjudication, the Delhi ITAT admitted the assessee's additional evidence application qua comparables selection for AY 2005-06 and 2006-07. The ITAT Coram comprising Shamim Yahya and Anubhav Sharma observed that “either both TPO and …
