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2016 (4) TMI 1304

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..... he Appellant/Petitioner/Plaintiff: Padamchand Khincha, CA For the Respondents/Defendant: P.K. Srihari, Addl. CIT (DR) ORDER A.K. Garodia, Member (A) 1. These are cross appeals filed by the assessee and the Revenue which are directed against the order of ld. CIT (Appeals)-IV Bangalore dated 18.12.2012 for the assessment year 2008-09. 2. The grounds raised by the assessee in its appeal are as under:-- GROUNDS RELATING TO LEGAL ISSUES 1. The Order of the learned Commissioner of Income Tax (Appeals) - IV to the extent prejudicial to the appellant is bad in law. 2. The learned Assessing Officer has erred in making a reference to Transfer Pricing Officer for determining arm's length price without demonstrating as to why it was necessary and expedient to do so. The learned Commissioner of Income Tax (Appeals) - IV has erred in confirming the action of the Assessing officer. 3. The learned Assessing Officer, learned Transfer Pricing Officer and Commissioner of Income Tax (Appeals) - IV have erred in a. Passing the Orders in the manner passed by them. The Orders being bad in law are liable to be quashed. b. passing the order without demonstrating tha .....

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..... fficer, learned Transfer Pricing Officer and Commissioner of Income Tax (Appeals) - IV have erred in not allowing the benefit of the +/- 5% range prescribed in the proviso to section 92C(2). 8. The learned assessing officer has erred in levying interest under section 234B and 234D of the Income tax Act, 1961. On facts and in the circumstances of the case and law applicable, interest under section 234B and 234D is not leviable. The appellant denies its liability to pay interest under section 234B and 234D. PRAYER 9. On an overall consideration of the facts of the case, and the law applicable: a. the ALP as determined by the Transfer Pricing Officer, as adopted by the Assessing Officer and as confirmed by the CIT(A), to the extent prejudicial to the appellant, being not correct is to be quashed and the figures as determined and returned by the appellant being correct are to be accepted. b. Interest under section 234B and 234D be deleted. The appellant submits that each of the above grounds/sub-grounds are independent and without prejudice to one another. The appellant craves leave to add, alter, vary, omit, substitute or amend the above grounds of appeal, at any .....

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..... delivery of the product or software outside India, excluded from export turnover by the AO and accordingly modify the computation of relief allowable under section 10A. 12. The CIT(A) erred in not appreciating that there is no provision in the Act which requires the concerned expenses which are required to be reduced from the export turnover as per clause (iv) of the Explanation to section 10A to be reduced from the total turnover. 13. For these and such other grounds that may be urged at the time of hearing, it is humbly prayed that the order of the CIT (A) be reversed and that of the Assessing Officer be restored. 14. The appellant craves leave to add, to alter, to amend or to delete any of the grounds that may be urged at the time of hearing of the appeal. 4. At the outset, it was submitted by the ld. AR of assessee that as per Tribunal's order rendered in the case of Kodiak Networks India Pvt. Ltd. v. DCIT in IT(TP)A No. 1540/Bang/2012 dated 05.06.2015 for the same assessment year (copy available at pages 236 to 290 of PB), the Tribunal has decided similar issue under similar facts in favour of the assessee, by following various other Tribunal's orders an .....

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..... omparables and inclusion of one comparable i.e., VGL Softech Ltd. are different than the basis and reasoning given by the Tribunal in the case of Kodiak Networks India Pvt. Ltd. v. DCIT (supra) and therefore, the matter may be restored to the file of AO/TPO for fresh decision. 9. Regarding ground No. 6 raised by the Revenue, it is submitted by the ld. DR of the Revenue that the working of CIT (Appeals) regarding net margin of the comparable i.e., KALS Information Systems Ltd. at 30.92% as against 41.94% computed by the TPO is not correct. At this juncture, it was pointed out by the Bench that as per the Tribunal's order in the case of Kodiak Networks India Pvt. Ltd. v. DCIT (supra), when this comparable i.e., KALS Information Systems Ltd. has to be excluded, then the percentage of margin of that comparable is not relevant and the same is of academic interest only. In reply, the ld. DR of Revenue had nothing to say. 10. Regarding ground Nos. 11 12 of the Revenue's appeal, it was submitted by the ld. DR of Revenue that lease line charges of ₹ 6,41,835 and foreign exchange loss of ₹ 45,97,211 attributable to delivery of the product or software outside I .....

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..... ii) Customer and support services being ITES . We will first take up the issue of Transfer Pricing Adjustment in respect of international transaction of providing software development services to the AE. The software applications developed by the assessee are in the field of telecom call processing, element management systems and signaling protocol adoption. The architecture and specifications for the application are developed by the associated enterprise based on which the assessee develops the software modules and delivers the same to the associated enterprise. Thus, the assessee is providing purely software development services to its AE. In its Transfer Price study analysis the assessee has bench marked its services by adopting the Transactional Net Margin Method (TNMM) as most appropriate method with OP/TC as Profit Level Indicator (PLI) and selected 17 comparables. The assessee has computed arithmetic mean of the comparables at 14.76% in comparison to the assessee's operating margin on cost at 10.73% and accordingly the assessee claimed that margin of the assessee is within 5% range of the Arms'' Length Price (AL)/arithmetic mean of the comparables. The TPO rej .....

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..... n various cases has held that these companies cannot be considered as comparables with the software development services as provided by the assessee. He has also invited our attention to various decisions of this Tribunal wherein these companies were rejected as comparables of software development services provider. Apart from these 12 companies, the ld.AR is also seeking exclusion of M/s. Bodhtree Ltd. from the list of comparables as additional ground raised by the assessee on the ground that in case of M/s. Mindtech (India) Ltd., v. DCIT in IT(TP) No. 70/Ban/2014 (AY-2009-10) dated 21.8.2014 this Tribunal has held that M/s. Bodhtree Ltd. cannot be considered as comparables. Thus, the ld. AR has submitted that after excluding these 13 companies from the list of comparables the mean margin of remaining companies selected by the TPO comes to 13.72% and after adjustment of working capital it comes to 13.50% in comparison the operating martin of the assessee at 11.30% which is within the range of 5% and therefore no adjustment is called for. 20. On the other hand, the ld. DR submitted that TPO took segmental data in case of M/s. KALS Information Systems Ltd. (Seg.), M/s. Tata El .....

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..... functionally comparable to the assessee as it is into software products whereas the assessee offers software development services to its AEs. The TPO had rejected the objections of the assessee on the ground that this comparable company has categorized itself as a pure software developer, just like the assessee, and hence selected this company as a comparable. For this purpose, the TPO had relied on information submitted by this company in response to enquiries carried out under section 133(6) of the Act for collecting information about the company directly. 7.2 Before us, the learned Authorised Representative reiterated the assessee's objections for the inclusion of this company from the list of comparable companies on the ground that this company is not functionally comparable to the assessee as it is into software products. It is also submitted that the segmental details of this company are not available and the Annual Report available in the public domain is not complete. It was further contended that the information obtained by the TPO under section 133(6) of the Act, on the basis of which the TPO included this company in the final list of comparable companies, has not .....

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..... Unless the facts and the FAR analysis of Triology case are comparable to that of the assessee in the case on hand, comparison between the two is not tenable. (ii) After demonstrating the similarity and the comparability between the assessee and the Triology case, the assessee also needs to demonstrate that the facts applicable to the Assessment Year 2007-08, the year for which the decision in case of Triology E-Business Software India Pvt. Ltd. (supra) was rendered are also applicable to the year under consideration i.e. Assessment Year 2008-09. 9.5.3 It is a well settled principle that the assessee is required to perform FAR analysis for each year and it is quite possible that the FAR analysis can be different for each of the years. That being so, the principle applicable to one particular year cannot be extrapolated automatically and made applicable to subsequent years. To do that, it is necessary to first establish that the facts and attendant factors have remained the same so that the factors of comparability are the same. Viewed in that context, the assessee has not discharged the onus upon it to establish that the decision rendered in the case of Triology E-Business Softwa .....

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..... the order of the TPO/DRP for inclusion of this company Avani Cincom Technologies Ltd. in the final set of comparables. 7.6.1 We have heard both parties and perused and carefully considered the material on record. It is seen from the record that the TPO has included this company in the final set of comparables only on the basis of information obtained under section 133(6) of the Act. In these circumstances, it was the duty of the TPO to have necessarily furnished the information so gathered to the assessee and taken its submissions thereon into consideration before deciding to include this company in its final list of comparables. Nonfurnishing the information obtained under section 133(6) of the Act to the assessee has vitiated the selection of this company as a comparable. 7.6.2 We also find substantial merit in the contention of the learned Authorised Representative that this company has been selected by the TPO as an additional comparable only on the ground that this company was selected in the earlier year. Even in the earlier year, it is seen that this company was not selected IT(TP)A 1380/Bang/2012 Page 7 of 34 on the basis on any search process carried out by the TPO b .....

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..... ntra, the learned Departmental Representative opposed the exclusion of this company from the list of comparable companies. The learned Departmental Representative contended that since the assessee had accepted the TPO's proposal for inclusion of this company in the set of comparables and had not objected to its inclusion even before the DRP, the objections raised by the assessee in this regard, at this stage, ought to be rejected. 8.4.1 We have heard both parties and perused and carefully considered the material on record. Admittedly, there is no disputing the fact that the assessee had never objected to the inclusion of this company in the set of comparables in earlier proceedings before the TPO and the DRP. It is also seen that even in the grounds of appeal raised before us, the assessee has not raised any grounds challenging the inclusion of this company in the list of comparables. In fact in the assessee's own case for Assessment Year 2007-08, this company was selected as a comparable by the assessee itself. We, therefore, find no merit in the contentions raised by the learned Authorised Representative of the assessee in respect of this company at this stage of proce .....

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..... difference in functional comparability can be eliminated. By not resorting to such a process of making adjustments, the TPO has rendered this company as not qualifying for comparability. We therefore accept the plea of the assessee in this regard. (iv) The rejection/exclusion of this company as a comparable for Assessment Year 2007-08 for software service providers has been upheld by the co-ordinate benches of this Tribunal in the cases of LG Soft India Pvt. Ltd. in ITA No. 112/Bang/2011 , CSR India Pvt. Ltd. in IT (TP) A No. 1119/Bang/2011 and by the ITAT, Delhi Bench in the case of Transwitch India Pvt. Ltd. in ITA No. 6083/Del/2010 . (v) The facts pertaining to this company have not changed from Assessment Year 2007-08 to Assessment Year 2008-09 and therefore this company cannot be considered for the purpose of comparability in the instant case and hence ought to be rejected. In support of this contention, the assessee has also referred to and quoted from various parts of the Annual Report of the company. 9.3 Per contra, the learned Departmental Representative supported the inclusion of this company in the list of comparable companies. The learned Departmental Rep .....

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..... he list of comparables. The A.O./TPO are accordingly directed. 10. KALS Information Systems Ltd. 10.1 This is a comparable selected by the TPO. Before the TPO, the assessee had objected to the inclusion of this company in the set of comparables on grounds of functional differences and that the segmental details have not been provided in the Annual Report of the company with respect to software services revenue and software products revenue. The TPO, however, rejected the objections of the assessee observing that the software products and training constitutes only 4.24% of total revenues and the revenue from software development services constitutes more than 75% of the total operating revenues for the F.Y. 2007-08 and qualifies as a comparable by the service income filter. 10.2 Before us, the learned Authorised Representative contended that this company is not functionally comparable to the assessee and ought to be rejected/excluded from the list of comparables for the following reasons:-- (i) This company is functionally different from the software activity of the assessee as it is into software products. (ii) This company has been held to be functionally not compar .....

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..... record that the TPO has drawn conclusions as to the comparability of this company to the assessee based on information obtained u/s. 133(6) of the Act. This information which was not in the public domain ought not to have been used by the TPO, more so when the same is contrary to the Annual Report of the company, as pointed out by the learned Authorised Representative. We also find that the coordinate benches of this Tribunal in the assessee's own case for Assessment Year 2007-08 (supra) and in the case of Triology E-Business Software India Pvt. Ltd. (supra) have held that this company was developing software products and was not purely or mainly a software service provider. Apart from relying of the above cited decisions of coordinate benches of the Tribunal (supra), the assessee has also brought on record evidence from various portions of the company's Annual Report to establish that this company is IT(TP)A 1380/Bang/2012 Page 9 of 34 functionally dis-similar and different form the assessee and that since the findings rendered in the decisions of the coordinate benches of the Tribunal for Assessment Year 2007-08 (cited supra) are applicable for this year i.e. Assessment .....

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..... tial revenues from software products and the break up of such revenues is not available; (v) the company has incurred huge expenditure for research and development; (vi) the company has made arrangements towards acquisition of IPRs in 'AUTOLAY', a commercial application product used in designing high performance structural systems. In view of the above reasons, the learned Authorised Representative pleaded that, this company i.e. Infosys Technologies Ltd., be excluded from the list of comparable companies. 11.3 Per contra, opposing the contentions of the assessee, the learned Departmental Representative submitted that comparability cannot be decided merely on the basis of scale of operations and the brand attributable profit margins of this company have not been extraordinary. In view of this, the learned Departmental Representative supported the decision of the TPO to include this company in the list of comparable companies. 11.4 We have heard the rival submissions and perused and carefully considered the material on record. We find that the assessee has brought on record sufficient evidence to establish that this company is functionally dissimilar and diffe .....

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..... products and software services. (vi) the TPO has adopted consolidated financial statements for comparability purposes and for computing the margins, which is in contradiction to the TPO's own filter of rejecting companies with consolidated financial statements. 12.3 Per contra, the learned Departmental Representative supported the action of the TPO in including this company in the list of comparables. 12.4.1 We have heard both parties and carefully perused and considered the material on record. We find merit in the contentions of the assessee for exclusion of this company from the set of comparables. It is seen that this company is engaged both in software development and product development services. There is no information on the segmental bifurcation of revenue from sale of product and software services. The TPO appears to have adopted this company as a comparable without demonstrating how the company satisfies the software development sales 75% of the total revenue filter adopted by him. Another major flaw in the comparability analysis carried out by the TPO is that he adopted comparison of the consolidated financial statements of Wipro with the stand alone financi .....

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..... re development service provider. In the Annual Report of this company the description of the segment ' software development services' relates to design services and are not to software services provided by the assessee. (iv) Tata Elxsi Ltd. invests substantial funds in research and development activities which have resulted in the 'Embedded Product Design Services Segment' of the company to create a portfolio of reusable software components, ready to deploy frameworks, licensable IPs and products. The learned Authorised Representative pleads that in view of the above reasons; Tata Elxsi Ltd. is clearly functionally different/dis-similar from the assessee and therefore ought to be omitted from the list of comparables. 13.3 Per contra, the learned Departmental Representative supported the stand of the TPO in including this company in the list of comparables. 13.4 We have heard both parties and carefully perused and considered the material on record. From the details on record, we find that this company is predominantly engaged in product designing services and not purely software development services. The details in the Annual Report show that the segment so .....

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..... sisting of Web Strategy Services, I T design services and in Technology Consulting Services including product development consulting services. These services, the learned Authorised Representative contends, are high end ITES normally categorised as knowledge process Outsourcing ('KPO') services. It is further submitted that this company has not provided segmental data in its Annual Report. The learned Authorised Representative submits that since the Annual Report of the company does not contain detailed descriptive information on the business of the company, the assessee places reliance on the details available on the company's website which should be considered while evaluating the company's functional profile. It is also submitted by the learned Authorised Representative that KPO services are not comparable to software development services and therefore companies rendering KPO services ought not to be considered as comparable to software development companies and relied on the decision of the co-ordinate bench in the case of Capital IQ Information Systems (India) (P.) Ltd. v. Dy. CIT (International Taxation) [2013] 32 taxmann.com 21 (Hyd. - Trib.) and prayed tha .....

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..... d any separate segmental profit and loss account for software development services and product development services. (ii) In the case of E-Gain Communications (P.) Ltd. v. ITO [2009] 118 ITD [2008] 23 SOT 385 (Pune), the Tribunal has directed that this company be omitted as a comparable for software service providers, as its income includes income from sale of licences which has increased the margins of the company. The learned A.R. prayed that in the light of the above facts and in view of the afore cited decision of the Tribunal (supra), this company ought to be omitted from the list of comparables. 15.2 Per contra, the learned Departmental Representative supported the action of the TPO in including this company in the list of comparables. 15.3 We have heard the rival submissions and perused and carefully considered the material on record. It is seen from the material on record that the company is engaged in product development and earns revenue from sale of licenses and subscription. However, the segmental profit and loss accounts for software development services and product development are not given separately. Further, as pointed out by the learned Authorised Re .....

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..... clear that this company being into product development cannot be considered as a comparable to the assessee in the case on hand who is a software service provider and therefore this company i.e., Lucid software Ltd., ought to be omitted from the list of comparables. 16.2 per contra, the learned Departmental Representative supported the action and finding of the TPO in including this company in the list of comparables. 16.3 We have heard the rival submissions and perused and carefully considered the material on record. It is seen from the details on record that the company i.e. Lucid software Ltd., is engaged in the development of software products whereas the assessee, in the case on hand, is in the business of providing software development services. We also find that, co-ordinate benches of the Tribunal in the assessee's own case for Assessment Year 2007-08 (IT (TP) A No. 845/Bang/2011) , LG Soft India (P.) Ltd. (supra), CSR India (P.) Ltd. (supra); the ITAT, Mumbai Bench in the case of Telcordia Technologies India (P.) Ltd. (supra) and the Delhi ITAT in the case of Transwitch India (P.) Ltd. (supra) have held that since this company, is engaged in the software product .....

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..... s in the business of product design services. (iv) The ITAT, Mumbai Bench in the case of Telcordia Technologies India (P.) Ltd. (supra) while discussing the comparability of another company, namely Lucid Software Ltd. had rendered a finding that in the absence of segmental information, a company be taken into account for comparability analysis. This principle is squarely applicable to the company presently under consideration, which is into product development and product design services and for which the segmental data is not available. The learned Authorised Representative prays that in view of the above, this company i.e. Persistent Systems Ltd. be omitted from the list of comparables. 17.2 Per contra, the learned Departmental Representative support the action of the TPO in including this company in the list of comparables. 17.3 We have heard the rival submissions and perused and carefully considered the material on record. It is seen from the details on record that this company i.e. Persistent Systems Ltd., is engaged in product development and product design services while the assessee is a software development services provider. We find that, as submitted by the a .....

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..... which is as under: Quintegra has taken various measures to preserve its intellectual property. Accordingly, some of the products developed by the company ............... have been covered by the patent rights. The company has also applied for trade mark registration for one of its products, viz. Investor Protection Index Fund (IPIF). These measures will help the company enhance its products value and also mitigate risks. (iv) The TPO has applied the filter of excluding companies having peculiar economic circumstances. Quintegra fails the TPO's own filter since there have been acquisitions in this case, as is evidenced from the company's Annual Report for F.Y. 2007-08, the period under consideration. The learned Authorised Representative prays that in view of the submissions made above, it is clear that inter alia, this company i.e. Quintegra Solution Ltd. being functionally different and possessing its own intangibles/IPRs, it cannot be considered as a comparable to the assessee in the case on hand and therefore ought to be excluded from the list of comparables for the period under consideration. 18.3 Per contra, the learned Departmental Representative support .....

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..... services. Before us, in addition to the plea that the company was functionally different, the assessee submitted that this company was excluded from the list of comparables by the order of the co-ordinate bench of this Tribunal in the assessee's own case for Assessment Year 2007-08 (ITA No. 845/Bang./2011) on the ground that the 'Related Party Transactions ('RPT') is in excess of 15%. The learned Authorised Representative submitted that for the current period under consideration, the RPT is 18.3% and therefore this company requires to be omitted from the list of comparables. 19.2 Per contra, the learned Departmental Representative supported the action of the TPO in including this company in the list of comparables as this company was a pure software development service provider like the assessee. 19.3 We have heard both parties and perused and carefully considered the material on record. We find that the co-ordinate bench of this Tribunal in the assessee's own case for Assessment Year 2007-08 in ITA No. 845/Bang/2011 has excluded this company from the set of comparables for the reason that RPT is in excess of 15% following the decision of another benc .....

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..... issue in dispute was regarding TP adjustment in respect of software development activity of the assessee as in the present case. The 20 comparables selected by the TPO in the present case and in that case are the same. The reasoning given by the tribunal in that case for exclusion of 12 comparables is this that these companies are functionally dis-similar and different. In the present case, the function of the assessee company is claimed to be similar to that company i.e. Kodiak Networks India Pvt. Ltd. v. DCIT (supra) and the learned DR of the revenue could not point out any difference in the function of the present assessee company and that company i.e . Kodiak Networks India Pvt. Ltd. v. DCIT (supra). Therefore, by respectfully following that tribunal order, we hold that in the present case also, the same 12 comparables are to be excluded for working out the ALP, as was held by the Tribunal in that case. As per the working submitted by the ld.AR of the assessee, it is seen that when the said 12 comparables are excluded, the ALP as per the working of remaining 8 comparables is 14.35% without adjustment on account of working capital margin and 13.86% after adjustment on account .....

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..... te Bench's decision of the Tribunal and even if this comparable is included, this comparable has operating margin on cost of 12.39% and therefore, it will further reduce the arm's length margin computed at 13.86% on the basis of 8 comparables. Since inclusion or non-inclusion of this comparable i.e., M/s. VGL Softech Ltd. is not making any impact on the final decision because in both the situations, the arm's length margin remains within +/- 5% margin of the assessee's reported margin, we hold that this ground No. 3 of Revenue's appeal is of academic interest and therefore, we do not give any finding on this ground. 20. Regarding other 3 comparables as per grounds Nos. 4, 5 6 of the Revenue's appeal i.e., M/s. Avani Cincom Technologies Ltd., M/s. Celestial Biolabs Ltd., and KALS Information Systems Ltd.; we find that these 3 comparables are to be excluded as per decision of the coordinate Bench of Tribunal rendered in the case of Kodiak Networks India Pvt. Ltd. v. DCIT (supra) and therefore, there is no merit in these three grounds No. 4 to 6 of Revenue's appeal and the same are rejected. 21. We would also like to observe that in ground No. 6, .....

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