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2014 (12) TMI 1157 - ITAT CHENNAITransfer pricing adjustment - upward adjustment in Arm’s Length Price - selection of M/s Genesys International as comparable - Held that:- The assessee files before us annual report of this entity for 2008-09 stating it to be involved in land base mapping and in geographical information systems. This company also claims itself to be capable in GIS consulting, 3D mapping, Navigation maps, LiDAR, Photogrammetry remote sensing services, Utility services, Image processing, surveying, Business geographics & Logistics, Cadastral Mapping, City Scape and Telecommunications. These facts lead to an inference that there is mutually contradictory information in the public domain pertaining to the said entity. In other words, its functions in annual report and public domain differ. Faced with this situation, we are of the view that a remand order simpliciter will not meet the ends of justice. Thus, in the larger of interest of justice, we deem it appropriate that the impugned ‘PLI’ has to be decided somewhere between 20% and 32.8% i.e @ 23%. The assessee’s grounds are partly accepted. The Assessing Officer is directed to pass a consequential order computing upward adjustment accordingly. - Decided partly in favour of assessee.
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