Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2014 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (9) TMI 1163 - ITAT MUMBAIAdjustment to ALP of the international transactions - comparable selection criteria - Held that:- From the TPO report, we found that for the purpose of selection of comparables, the TPO had applied a filter of rejecting companies having employee costs less than 25% of revenues. However, the four companies as part of comparables selected by TPO fails the filter of 25% employee cost to the revenue. Since the employee cost to revenue ratio in case of these company is less than 25% of revenue, we restore the appeal back to the file of AO/TPO/DRP for considering afresh and applying the filter properly to the all comparables selected by TPO, keeping in view our above observation.
|