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2019 (10) TMI 1491 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- We have noticed that the turnover of the assessee herein for the year under consideration was ₹ 13.97 crores and hence it falls under the category of 1 - 200 crores as per Dun and Bradstreet's analysis. Hence the assessee should be compared with the companies having turnover in the above said range as per the decision rendered by the co-ordinate bench in the case of Genesis Integrating Systems India P Ltd. [2011 (8) TMI 952 - ITAT BANGALORE]. Since the turnover of following companies are more than 200 crores, they are liable to be excluded under turnover filter Infosys Ltd, Larsen & Toubro Infotech Ltd, Mindtree Ltd, Sasken Communication Technologies, Persistent Systems Ltd and Tata Elxsi (seg) Al following the decision of the co-ordinate bench rendered in the case of Electronics for Imaging India P Ltd. [2016 (2) TMI 1123 - ITAT BANGALORE] we direct the AO/TPO to exclude above said two companies ICRA Techno Analytics Ltd and KALS INFORMATION SYSTEMS Ltd also. Determining the ALP - We direct the AO to compute margins by taking foreign exchange fluctuations gains/loss as part of operating income both in the case of the assessee and comparable companies.
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