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2016 (4) TMI 1136 - BOMBAY HIGH COURTTransfer pricing adjustment - selection of comparable - Held that:- As only persistently loss making unit cannot be said as comparable. In this case, the impugned order holds on facts that Capital Trust Ltd. it is not a persistent loss making unit. Therefore, Capital Trust Ltd. is comparable only persistently loss making unit cannot be said as comparable. In this case, the impugned order holds on facts that Capital Trust Ltd. it is not a persistent loss making unit. Therefore, Capital Trust Ltd. is comparable Spanco was essentially involved in activities with regard to Telecom and providing call center services while the Respondent-Assessee was providing financial services. Thus, as the activities of Spanco and Respondent-Assessee are functionally different, they are not comparable Tribunal in the impugned order adopted the same comparable it had adopted in the case of M/s. Carlyle India (2013 (4) TMI 486 - BOMBAY HIGH COURT ) for the purpose of arriving at the ALP in respect of its International Transaction. No substantial question of law arises in this case.
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