Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2016 (12) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2016 (12) TMI 1607 - AT - Income TaxTPA - ALP determination - TNMM used as the most appropriate method to arrive at Arms length price (ALP) - comparables selection - Held that:- Assessee has been treated as a low end ITES service provider, rendering data processing or an IT enabled services, who is not involved in domain knowledge, so as to include any KPO service provider as a comparable. Companies functionally dissimilar with that of assessee need to be deselected from final list of comparability. Deduction under section 10A being granted on the gross total income - set of the brought forward losses of assessment year 2001-02 and 2002-03 against the balance profit under the head claimed - Held that:- No infirmity in the directions given by Ld.CIT(A), in computing deduction under section 10 A before carry forward of losses. Accordingly this ground raised by revenue stands dismissed. See CIT vs. Black & Veatch Consulting Pvt. Ltd.[2012 (4) TMI 450 - BOMBAY HIGH COURT]
|