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Showing 41 to 60 of 521 Records Search Text: service tax medical transcription |
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2018 (12) TMI 326 - ITAT DELHI TPA - comparable selection criteria - Held that:- The assessee provided software development services (CSD), information technology enabled services (ITES), marketing support services (MSS) to its associated Enterprises (AEs) on cost-plus basis, purchased fixed assets and availed legal, finance, human resource, IT support and other support services from AEs, thus companies functionally dissimilar with that of assessee need to deselected from final list. Exclude the Infosys BPO Ltd on the basis o... ... ...
2021 (5) TMI 1049 - ITAT MUMBAI TP Adjustment - comparable selection - TPO rejected / excluded the comparables selected by the assessee (being non KPO) and further selected / included KPO companies as comparable to the assessee - HELD THAT:-assessee is a captive service provider providing Information Technology Enabled Service (ITES) to its Associated Enterprises (A.E) globally and the assessee s margin from the said international transaction for the assessment year 2009 10 is 23.07%. The assessee is providing only ITES servic... ... ...
2020 (9) TMI 911 - ITAT BANGALORE TP Adjustment - determination of Arms Length Price (ALP) in respect of the international transaction of rendering ITeS to the AE - Comparable selection - distinction between the KPO BPO - HELD THAT:- Assessee in engaged in the business of provision of Information Technology Enabled Services (ITES) to its wholly owned holding company thus companies functionally dissimilar with that of assessee need to be deselected from final list. Companies providing high end services cannot be compared to compa... ... ...
2017 (12) TMI 1731 - ITAT DELHI Addition on account of arm s length price - Comparable selection - HELD THAT:- When we examine the services rendered by the taxpayer to its AE in the light of the fact that the taxpayer is a risk free entity working on cost plus mark up and does not own any intangibles, the taxpayer is a low end BPO. Accentia Technologies Ltd. (Seg.) - extra ordinary growth, extra ordinary operating cost towards overseas business expenses and substantial market cost towards overseas business expenses, it leads t... ... ...
2016 (4) TMI 356 - ITAT DELHI Transfer pricing adjustment - exclusion of Mold-Tek Technologies Ltd as comparable by the CIT(A) - Held that:- The company grew with a compounded annual growth rate (CAGR) of 147% for 3 years which is evident from the chart given in the impugned order of the Ld.CIT(A) and on the basis of the said chart, CIT(A) has rightly rejected Mold-Tek as comparable company due to the consistently abnormal profits earned by the company. The CIT(A) by deciding this issue has studied annual report of the compa... ... ...
2022 (7) TMI 1401 - ITAT BANGALORE TP Adjustment - Comparable selection - HELD THAT:- Exclusion of companies as functionally dissimilar with that of assessee need to be deselected from final list. Adjustment on account of notional interest on outstanding receivables - Whether Outstanding receivables cannot be treated as a separate international transaction? - HELD THAT:- The assessee has provided IT enabled services to its AEs and amount outstanding as trade receivables merely represent the dues which are to be received by the As... ... ...
2020 (12) TMI 469 - ITAT BANGALORE TP Adjustment - Comparable selection - HELD THAT:- As regards exclusion of comparables, the assessee has demonstrated that Accentia Technologies Ltd. and Fortune Infotech Ltd. both are functionally dissimilar to assessee s ITeS Segment. In fact in Accentia Technologies Ltd. there is an influence to the pricing policy because of its possession of Brand Value/IPRs. Accentia Technologies Ltd. has also made acquisition/amalgamation which depicts that the company had plans to grow through tie-ups and... ... ...
2020 (4) TMI 913 - ITAT MUMBAI TP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- CG Vak Software Exports Ltd. company excluded as it is consistent loss making company - We noted that before the DRP the assessee stated that this comparable is having profit in the current year at 7.14% and can be considered as a comparable. It was also stated that merely because a company is incurring losses, it would not lose its status as a comparable and that losses and incidental of business which is at par with ... ... ...
2019 (9) TMI 972 - ITAT MUMBAI TP Adjustment - comparable selection - HELD THAT:- Assessee is engaged in providing IT Support (ITES), account reconciliation services etc to Morgan Stanley group entities/its AEs. In the international transaction of assessee was accepted at the ALP in earlier years, thus companies functionally with that of assessee need to be deselected from final list.... ... ...
2018 (10) TMI 70 - ITAT DELHI TPA - ALP determination - MAM Selection - comparable selection - Functional profile of company - Held that:- Functional profile of the assessee has remained unchanged from past year and the assessee continues to be a development centre undertaking contract R&D activities with insignificant risk as per Circular 6/2013. The above discussion brings us to an irresistible conclusion that the assessee is a contract R&D service provider, thus removal of companies from final list as functionally differe... ... ...
2018 (4) TMI 82 - ITAT BANGALORE TPA - comparable selection criteria - Held that:- Assessee is engaged in the business of rendering software development and ITES and IT services, thus companies functionally dissimlar with that of assessee need to be deselected from final list. Disallowance of depreciation under software on the ground that the TDS was not deducted at source - Held that:- The assessee lower authorities was not correct in not allowing the depreciation on the software and therefore we direct the AO to allow the dep... ... ...
2017 (11) TMI 1592 - ITAT DELHI TP adjustment - selection of comparable - Held that:- Assessee is into rendering ITES services, thus companies functionally dissimlar with that of assessee need to be deselected from final list of comparable.... ... ...
2017 (10) TMI 49 - ITAT DELHI TPA - selection of comparable - selection criteria - Held that:- The assessee under the provision of software research and development services carries out R products to be developed or used; timeline for completion and specific result to be achieved. The entire conceptualizing of the marketing strategy for sales of its products and services, securing of orders of its products are done by CDS and not by the assessee. The assessee company is purely a ‘captive service provider’ and does not undert... ... ...
2017 (1) TMI 1556 - ITAT PUNE Eligibility to deduction claimed u/s 10B - alternate claim of section 10A deduction - Held that:- The issue which arises before us is identical to the issue before the Tribunal in assessment year 2009-10 [2015 (3) TMI 151 - ITAT PUNE]. The year under appeal before us is assessment year 2010-11 and following the same parity of reasoning, we hold that the assessee is not entitled to the claim of deduction under section 10B of the Act. However, eligibility of deduction under section 10A of the Act ... ... ...
2017 (8) TMI 225 - ITAT DELHI Transfer pricing adjustment - difference in Arm’s Length Price (ALP) of the international transaction relating to IT enabled services - selection of comparabale - Held that:- The assessee is wholly owned subsidiary of Exl Holdings and was engaged in business of rendering of transaction processing services and internet & voice based customer care services for its worldwide clients. The assessee furnished TP study and selected TNMM as the most appropriate method to benchmark its international tran... ... ...
2016 (11) TMI 1566 - ITAT BANGALORE TPA - comparable selection - functinal dissimilarity - Held that:- Assessee is engaged in the business of providing medical transcription services falling within the category of information technology enabled services [“ITES”] to its AEs i.e., Acusis LLC, USA thus companies functionally dissimilar with that of assessee need to be deselected from final list.... ... ...
2016 (3) TMI 356 - ITAT BANGALORE Transfer pricing adjustment - whether the foreign exchange gain/income from service provided to AE will be part of the operating revenue/income? - Held that:- In view of the coordinate bench of the Tribunal in the case of Rusabh Diamonds (2013 (11) TMI 520 - ITAT MUMBAI ), we hold that the foreign exchange gain/income from service provided to AE will be part of the operating revenue/income of the assessee and consequently it will be part of the operating profit of the assessee for the purpose of... ... ...
2010 (6) TMI 650 - ITAT DELHI R.P. TOLANI AND K.G. BANSAL, JJ.
Manish Gupta for the Appellant.
Vinod Kumar Bindal and Ms. Sweeti Kothari for the Respondent.
ORDER
K.G. Bansal, Accountant Member. - All these appeals of the Revenue raise a common ground that on the facts and in the circumstances of the case, the learned CIT(A) erred in allowing deduction under section. 10B of the Income-tax Act, 1961, ignoring the fact that the assessee did not fulfil the conditions mentioned in sub-section (2) of this section. It ... ... ...
2025 (5) TMI 1077 - ITAT MUMBAI The SC/Tribunal addressed multiple tax-related issues for a banking entity, focusing on transfer pricing, derivative losses, exempt income expenses, and bad debt claims. The key outcome involved partially allowing the assessee's claims across various tax provisions. The Tribunal directed recalculation of transfer pricing adjustments, permitted mark-to-market losses on derivatives, and remanded several issues for detailed verification, ultimately providing significant relief to the taxpayer while maintaining procedural compliance.
2025 (3) TMI 640 - ITAT BANGALORE TP Adjustment - treating services (tangible and intangible) provided by the AE, free of cost, as a part operating cost to the assessee - whether the notional cost is to be treated as part of operating cost of the assessee to work out the PLI of the assessee - HELD THAT:- As we can safely conclude that the stand of the lower authorities for including the notional cost in calculating the PLI of the assessee in the given facts and circumstances is not sustainable. It is necessary to take a note of ... ... ...
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