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2019 (10) TMI 1286 - ITAT BANGALORE TP Adjustment - comparability - HELD THAT:- Companies functionally comparable with ITES only need to be included in final list of comparability. TCS E Service Ltd., should be excluded from the list of comparable companies. Whether foreign exchange fluctuation gain or loss should be considered as part of the operating profit while computing the profit margin of the assessee as well as the comparable companies? - main reason why the DRP considered foreign exchange gain should not be treated as a p... ... ...
2019 (8) TMI 1630 - ITAT PUNE TP Adjustment - Comparable selection - HELD THAT:- Bodhtree Consulting Ltd. should be deleted from the final list of comparables. KALs Information Technology Systems Ltd. is engaged in selling of software products which is different from the activities undertaken by assessee, namely, rendering of software service only to its AEs, we hold the same to be incomparable and accordingly direct to exclude it from the final list of comparables. Infosys Technologies Ltd. - There is no match as compared t... ... ...
2019 (6) TMI 1489 - ITAT MUMBAI Disallowance of depreciation on assets leased (finance lease) - AO has disallowed depreciation claim merely on the ground that as per AS-19 issued ICAI, in finance lease the risk and rewards incidental to ownership of the asset transferred to the assessee - CIT-A deleted the disallowance - HELD THAT:- Assessee continued to have ownership of the asset even after leave and license agreement with Reliance Industries Ltd and the assessee has claimed depreciation for earlier two years. In fact, it ha... ... ...
2019 (6) TMI 1696 - ITAT DELHI TP Adjustment - Comparable selection - HELD THAT:- Tata Consultancy Services Ltd (TCS) has expended Rs.42.31 crores on its R D and a highly risk bearing company and as such, cannot be a suitable comparable vis- -vis taxpayer which is a captive software provider being remunerated on cost plus mark up basis for rendering 100% services to its AE. Thus we direct Ld. TPO to exclude this company from final set of comparables. Infosys Ltd. company has been ordered to be excluded in case cited as CIT v.... ... ...
2019 (1) TMI 1866 - ITAT BANGALORE TP Adjustment - comparability - Considering R Systems International Ltd. as comparable - HELD THAT:- As rightly pointed out by the ld. AR, Rule 10(B)(4) does not exclude from consideration the data of an entity merely because its financial year is different from the financial year of the assessee. What the Rule requires is that the data to be used in analyzing the financial results of an uncontrolled transaction with an international transaction shall be the data relating to the financial year i... ... ...
2018 (9) TMI 1949 - ITAT DELHI TP Adjustment - Comparable selection - HELD THAT:- The appellant company is a Business Process Outsourcing company, set up as a captive service provider to provide offshore outsourcing services primarily to various GE entities/ businesses worldwide. The primary activity of the appellant company comprises of rendering IT Enabled Services ( ITES ) and financial support services to various overseas GE Group companies. In return for rendering these services, the appellant was remunerated on an arm s... ... ...
2018 (4) TMI 1621 - ITAT DELHI Disallowance of deduction u/s 10B - Held that:- Since in the year under consideration also the assessee has made alternative claim for allowing deduction under section 10A of the Act, we, therefore, respectfully restore the matter to the file of the Assessing Officer for examining the claim of the assessee for allowing deduction under section 10A of the Act. It is needless to mention that assessee shall be afforded adequate opportunity of being heard. Accordingly, relevant grounds of the appeal ... ... ...
2017 (8) TMI 1050 - CESTAT MUMBAI Export of services - promotion and marketing of spares and accessories of Yamazaki Mazak Trading Corporation, Japan(YMTCJ) and they have received commissioner from YMTCJ - appellants are involved in various activities in India on behalf of the foreign principals for a consideration - extended period of limitation - Held that: - it is apparent in terms of circular dated 24-2-2009, the Indian agent who undertake marketing in India of goods of foreign seller and received the commission for the serv... ... ...
2017 (4) TMI 358 - ITAT HYDERABAD Taxing of accrued income shown as unmatured advances in the balance sheet - Held that:- The issue is covered in favour of the assessee by the decision of the ITAT, Hyderabad in assessee’s own case for AY 2001-02 what is to be seen is whether the assessee has followed a recognized method of accounting or not. If method followed by the assessee is such whereby correct income cannot be deduced, then only the assessing officer has the authority to adopt a reasonable basis to determine the total inco... ... ...
2017 (1) TMI 1489 - ITAT HYDERABAD TPA - comparable selection criteria - Held that:- Assessee is engaged in the business of computer software development services, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Computation of deduction u/s 10A - Held that:- Action of the DRP in directing the AO to exclude data link charges and freight charges both from turnover as well as total turnover while computing deduction u/s 10A, we do not find any infirmity in the order of the DRP as i... ... ...
2016 (6) TMI 1259 - ITAT DELHI TPA - comparable selection criteria - Held that:- Assessee is engaged in providing software development services (SDS), IT enabled services (ITES) and market support services (MSS) to its AEs. The company is primarily engaged in the business of software development for export, more specifically, the assessee is involved in development of switching integration and comer stone modules for Janus release, a next generation messaging products, thus companies functionally dissimilar with that of asses... ... ...
2016 (3) TMI 1300 - ITAT BANGALORE Calculating deduction u/s. 10A - Held that:- It is admitted that on a parity of comparison, whatever is reduced from the export turnover has to be reduced from the total turnover and this principle was accepted by the jurisdictional Karnataka High Court in the case of CIT Vs. Tata Elxsi Ltd. [2011 (8) TMI 782 - KARNATAKA HIGH COURT] which the Ld CIT(A) has followed. We do not see any reason to interfere with the above. Comparable selection - TPA - functional dissimilarity - Held that:- Assessee ... ... ...
2015 (1) TMI 917 - ITAT MUMBAI Transfer pricing adjustment - selection of comparables - Held that:- Coral Hubs Ltd. (Vishal Information Technologies Ltd.) has to be excluded from the list of final comparables on the ground that this company has outsourced its considerable portion of its ITES business, whereas the assessee is carrying out entire operation by itself. M/s. Eclerx Services Ltd. has to be excluded from the list of final comparables as if the functions actually performed by the assessee company for its AEs are comp... ... ...
2014 (7) TMI 1239 - KARNATAKA HIGH COURT Entitlement to benefit under Section 10A - substantial value addition made before the product is delivered - products manufactured and produced by third parties - assessee is in the business of providing medical transcription facilities - Held that:- Assessee is in the business of transcribing medical transcription. It has outsourced portion of its work as done by the sub contractor is in crude form and cannot be delivered in such form to the overseas customers. The assessee has to process the s... ... ...
Definitions The definitions related to the Safe Harbour Rules for International Transactions under the Income-tax Rules, 1962. It defines terms such as "accountant," "contract research and development services," "core auto components," "corporate guarantee," "employee cost," "generic pharmaceutical drug," "information technology enabled services," "intra-group loan," "knowledge process outsourcing services," "low value-adding intra-group services," "non-core auto components," "no tax or low tax country or territory," "operating expense," "operating revenue," "operating profit margin," "relevant previous year," and "software development services." These definitions are crucial for understanding the application of the Safe Harbour Rules.
2012 (6) TMI 478 - ITAT MUMBAI Transfer pricing - arm’s length price - addition on account of adjustment in respect of transactions with Associated Enterprises by taking profit margin at 27.84% as against margin of 20.17% of the assessee - Denial of plus / minus 5 % benefit – Held that:- TPO/AO erred and the Hon'ble DRP further erred in upholding / confirming the action of the learned TPO/AO in denying the benefit / reduction of 5 percent from the arithmetic mean as provided in proviso to Section 92C(2) of the Act while compu... ... ...
Clarification on changes proposed in the Finance Bill, 2006 The Finance Bill, 2006 introduces significant changes to the service tax regime, including an increase in the service tax rate from 10% to 12%. New taxable services are specified, and the scope of existing services is clarified. Key amendments include the inclusion of services provided by unincorporated associations to their members as taxable, expansion of service provider definitions from 'commercial concern' to 'person', and the introduction of reverse charge mechanisms for services provided from outside India. Certain exemptions are withdrawn, while new exemptions are introduced. Procedural changes in the Service Tax Rules, 1994 are also outlined.
2022 (3) TMI 1476 - ITAT MUMBAI TP Adjustment - comparable selection - HELD THAT:- Rejection of companies non-comparable to assessee s international transaction of Information Technology Enabled Services. We noticed that the Cosmic Global Limited was excluded from the comparables in the earlier Assessment Years and the Coordinate Benches consistently confirmed the same. The major part of the income is from translation charges and functions of this comparable is different to the assessee company, therefore consistent with the e... ... ...
2020 (11) TMI 1093 - ITAT DELHI TP Adjustment - comparable selection - HELD THAT:- Accentia technologies Ltd - We find that the revenue shown by this comparable company is only medical transcription, billing and collection and income from coding. We do not find any product sale by this comparable company, therefore, the reason given by the learned Dispute Resolution Panel for exclusion of this comparable company is devoid of any merit. Therefore, we reverse the finding of the learned Dispute Resolution Panel and direct the lea... ... ...
2020 (11) TMI 651 - ITAT DELHI TP Adjustment - comparable selection - Comparability analysis - HELD THAT:- Accentia technologies Ltd - Several judgments relied upon wherein this comparable is rejected on functionally being different and absence of any segmental data as well as occurring of any extraordinary events as discussed above did not happen in the case of this comparable for this year. In view of this, the decisions relied upon by the assessee does not help the case for exclusion of the above comparable. In view of thi... ... ...
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