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2013 (9) TMI 1069 - AT - Income TaxTransfer pricing adjustment - comparability - Held that:- Those companies ( like Infosys and others) are full fledged risk bearing companies and are functionally dissimilar as a comparable to assessee who is a captive software service provider. Addition u/s 14A - Held that:- It has not been disputed that no borrowed funds were utilized for investment in mutual funds. Consequently, the average cost of investment almost becomes nil. However, various courts have held that the investment and consequent earnings have back up of the administrative infrastructure. Keeping in view the same, we are inclined to restrict the estimated disallowance u/s 14A in this behalf @ 10% of the dividend i.e. 57,580/-. This ground is partly allowed.
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