Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2015 (7) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2015 (7) TMI 1220 - AT - Income TaxTransfer pricing adjustment - comparability - Held that:- As it is clear from the business profile of the assessee recorded by the TPO that the international transactions in the ITES pertaining to data processing and in the nature back end service support to the AE group of Co's, thus companies functionality dissmilar with that of assessee need to be deselected from final list of comparable. In view of the statement and plea of the learned AR we direct the AO/TPO to re-compute the ALP after excluding the above two Co. namely M/s Eclerx and M/s Mold Tek (Supra) and then determine the adjustment, if any after giving the benefit of tolerance range of +=5%. Computation of deduction u/s 10A - Held that:- The communication expenses are excluded from the export turnover then, the same should also be excluded from the total turnover in view of the judgment in the case of CIT v. Tata Elxsi Ltd. [2011 (8) TMI 782 - KARNATAKA HIGH COURT] for the assessment year 2003-04.
|