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2016 (7) TMI 1445 - ITAT MUMBAITPA - Selection of comparables - transfer pricing adjustment relating to information technology and network support service - Held that:- Companies which are having more than 20 times the turnover of the assessee from software development services segment cannot be treated as comparables - thus AO / Transfer Pricing Officer is directed to determine arm's length price afresh after removing the companies having turnover of more than ₹ 20 crore - companies being functionally different with that of assessee who is rpoviding information technology and network support services are to be removed from the selection of comparables. E-connectivity charges - revenue v/s capital - Held that:- The expenditure incurred by the assessee is not for acquiring any software - following the view in assesse's own case of UCB INDIA PVT. LTD. VERSUS THE ITO 7 (3) -3, AAYAKAR BHAVAN, MUMBAI AND VICE-VERSA [2016 (5) TMI 1276 - ITAT MUMBAI] we hold that the e-connectivity charges paid by the assessee are of Revenue in nature
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