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2016 (2) TMI 932 - ITAT PUNETransfer pricing adjustment - selection of comparables - Held that:- (i) KALS Information Systems Ltd., (ii) eZest Solutions Ltd. and (iii) Bodhtree Consulting Ltd. were engaged in ITES services and hence, the same being functionally dissimilar, should be excluded from the final set of comparables. Genesys International Corporation Ltd as not functionally similar to the assessee, the said concern is to be excluded from the final list of comparables and accordingly, we direct so. Goldstone Technologies Ltd. was engaged in the activities related to Media & IP TV and further, the company had carried inventory of set top boxes and movie rights in its Balance Sheet for the previous year. In addition, the said company had some income from sale of industrial material. Looking at the services provided by the said concern, it is clear that the same are functionally dissimilar to the services provided by the assessee and there is no merit in comparing the results of the said concern while benchmarking the international transaction of the assessee. Accordingly, we direct the Assessing Officer to exclude Goldstone Technologies Ltd. Working capital adjustment - Held that:- We direct the Assessing Officer to re-compute the working capital adjustment in the hands of assessee in line with the directions given by the Tribunal in assessment year 2007-08 wherein have given directions for allowing working capital adjustment as per OECD guidelines.
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