M/S. PENTAIR WATER INDIA PVT. LTD. Vs. ADDL. COMMISSIONER OF INCOME TAX, MARGAO RANGE, MARGAO, GOA
LAWS(IT)-2014-5-134
INCOME TAX APPELLATE TRIBUNAL
Decided on May 23,2014

Appellant
VERSUS
Respondents

JUDGEMENT

P.K. Bansal, Member (A) - (1.) THESE cross -appeals have been filed against the orders of CIT(A) -IV, Bengaluru dt. 16.11.2012 for A.Y. 2007 -08.
(2.) THE Assessee in his appeal for A.Y. 2007 -08 has taken the following effective grounds of appeal: 2. The Ld. CIT(A) erred in denying appellant's claim of depreciation on UPS at the rate of 60% as is applicable for computers (vide para 20 on page 7 of the appeal order). The Ld. CIT(A) erred in calculating the operating margin of comparable companies engaged in ITES sector @ 22.92% as against the margin calculated by appellant company @ 16.56% for the purposes of computing Arm's length Price (ALP) for Transfer Price Adjustment in relation to CDR division of the appellant (vide para 68 on page 21 of the appeal order).
(3.) THE Ld. CIT(A) erred in not allowing an adjustment of 1.10% in the operating margin of CDR unit in computation of ALP for Transfer Price Adjustment, as asked for by appellant, in relation to work performed by CDR unit of the company for its manufacturing plant at Goa and disregarding revenue of Rs. 12,08,000/ - (vide para 69 on page 21 of the appeal order).;


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