Segmental accounts of the assessee is required in determination of assesses profit to total cost from international transaction
Court :
INCOME TAX APPELLATE TRIBUNAL
Brief :
After considering the rival submissions and perusing the relevant material on record, it is observed that similar disallowance was made by the AO in the immediately preceding assessment year i.e. 2005-06. The Tribunal, vide its order dated 31-01-2012 in ITA No.4089/Mum/2011 for such preceding year has restored the matter to the file of AO for taking a fresh decision in the light of the guidelines laid down in para-13. Both the sides are in agreement that the facts and circumstances of the instant year are mutatis mutandis similar to those of the immediately preceding year. Respectfully following the precedent, we set aside the assessment order on this point and direct the AO to re-decide this issue in consonance with the observations made by the Tribunal in the immediately preceding year.
Citation :
Hinduja Ventures Ltd.,49/50, In Centre, MIDC,12th Road, Marol, Andheri (E),Mumbai-400 093.PAN: AAACH2058H.Appellant Vs. Addl. Commr. of Income-tax,Range 8(2), Aaykar Bhavan,M.K. Road,Mumbai-400 020. Respondent
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Ayush
Published in Income Tax
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