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2016 (10) TMI 1313 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Acropetal Technologies Ltd. - Rejection of this company as comparable to low end BPO service providers on the reasoning that this company is providing KPO services. R. Systems International ltd. - Remit the issue of comparability of this company to the AO/TPO for examining afresh in the light of the relevant judicial precedents and of course after due opportunity of being heard to the assessee. Aditya Birla Minacs Word Wide Ltd. and Tata communication transformation Ltd. - Assessee’s contention in relation to application of RPT filter to these two comparables needs to be looked into fresh keeping in view the observations of the ITAT in case of Nokia India (P) Ltd. v/s DCIT [2014 (11) TMI 101 - ITAT DELHI] - We, therefore, remit the issue of comparability of the aforesaid two comparables to the Assessing Officer / Transfer Pricing Officer for deciding afresh after due opportunity of being heard to the assessee.
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