Home
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2015 (10) TMI 2626 - HC - Income TaxTPA - exclusion of two companies Cosmic Global Limited (‘CGL’) and Accentia Technologies Limited (‘ATL’) from the list of comparables for the purposes of determining the arm’s length price (‘ALP’) of the international transaction of ‘provision of ITES’ involving the Respondent Assessee - Held that:- One reason for exclusion of CGL was that it had outsourced its major activities whereas the Assessee was doing the business in-house. As far as ATL is concerned, it was noticed that there was merger of some other entity with it and, therefore, the said company could not be considered as a comparable. The submission of learned counsel for the Revenue is that both these companies were included in the Assessee’s own list of selected entities and the demand for the exclusion was made only before the ITAT. Be that as it may, the Court is of the view that the order of the ITAT in so far as it concerns the exclusion of the above entities from the list of comparables does not give rise to any substantial question of law which requires consideration by the Court.
|