Moreover, once an audited segment accounts have been furnished and no fault has been found, the same cannot be rejected on the reasoning given by the learned Departmental Representative and, hence, it should be accepted.
These credentials have seen him contribute significantly in his previous assignments at Geosansar Advisors Pvt. This view has now further been clarified by the amendment to the proviso to Section 92C 4by the Finance Act w.
Raw naphtha is one such stage. Counsel that bench marking should be done only on A. It has also failed to segregate the income and cost relating to various activities being undertaken by the assessee which have been aggregated, over all margin.
He further submitted that if a comparison of operating margin at segmental level is taken into consideration vis-a-vis A.
It can always grant a licence in respect of any patent or design to a third party. Actual transaction with A. The main business of the company is export and import of home and personal care products, beverages, export of rice and marine products, export and import of soap and toiletries. Insofar as the calculation furnished by the learned Departmental Representative is concerned, we do not find any merit in the said calculation in view of our analysis given above.
Bhushan has more than two-and-a-half decades of experience in capital markets and Government projects related to e-Governance. The TPO has virtually repeated the same adjustment made by the earlier TPO in his order dated 7th Marchby taking the average operating profit of the comparables at Lipton began to decline.
He was instrumental in setting up the Mutual Fund registry business for Karvy. By reason of such export, the Export Promotion Scheme applies.
He also referred to the orders of the Coordinate bench of the ITAT in assessment years andwherein in some oredes one of us Accountant Member is a party, to submit that there is no need for allocating the expenses.
He is a seasoned professional with an overall experience of more than a decade across Banking and Healthcare services.
There is no dispute that the assessee is entitled to the benefits of the provisions of sections HHI and IA. Recovery of expenses for common 67,20,96, TNMM corporate resources corporate audit Even after making the adjustment at the entity level, he made further adjustment on account of research innovation development related services.
Karvy Computershare has set new benchmarks in Investor Servicing by establishing performance standards for its Service Delivery. Chandra is also an entrepreneur.
The assessee, being aggrieved, is in further appeal before the Tribunal. The operating profit margins in case of 8 companies after excluding the company I.
The arithmetic mean of such comparables worked out at The position is as under: Therefore, the transactions of the assessee with the A. In the matter we would like to state that we are unable to locate any single FMCG company which is engaged in all the activities in which we are engaged.
Both the parties have also addressed us in detail with regard to the adjustment which has been added separately by the TPO and also the various other adjustments relating to royalty, etc.
Thus, there was no basis for doubting the allocation of pro-rata expenses and the operating margin of the various segments. In view of the stay granted in this appeal the issues have come up for consideration.
The TPO rejected all the objections and contentions of the assessee in a very detail manner which has been discussed from ParaMoneycontrol offers you a choice of email alerts on your investments for FREE!
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