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2014 (12) TMI 1212 - AT - Income TaxTransfer pricing adjustment - choice of comparable - Held that:- M/s. Artefact Projects Ltd. company is having a very high percentage of related party transaction, it cannot be considered as a comparable. We accept the contention of the Ld. Counsel and direct for the exclusion of this company from the final list of comparables. M/s.NTPC Electric Supply Ltd is a Government of India enterprise and is involved in enhancing and bringing sectoral reforms process and has been participating in various projects of distribution, infrastructural development programmes under consultancy assignments. Considering all these facts, this company is not functionally comparable. It is therefore directed to exclude this company from the final list of comparables. RITES Limited be excluded from the final list of comparables as it is in providing engineering services and to end to end solutions and therefore not functionally comparables with marketing support services. Water & Power Consultancy Services (India) Ltd. (Seg) be excluded from the final list of comparables as main fields of specialization of this company covered irrigation of drainage, flood control and Land Reclamation, River management dams, Reservoir Engineering and Barrages, Integrated Agriculture development, Watershed management, Hydropower and Thermal Power Generation, Power Transmission and Distribution , Rural Electrification, Ground Water Exploration, Minor irrigation etc
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