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2015 (4) TMI 1190 - AT - Income TaxTPA - comparable selection - selection criteria - Held that:- The Appellant provides mapping services mainly to COWI A/S, which is 59% of the total turnover of the Appellant. As per the functional analysis documented in the Transfer Pricing documentation, the Appellant can be is characterized as a service provider, which assumes less than normal risks associated with carrying out such business, companies functionally dissimilar with that of assessee need to be deselected from final list of comparability. Computing the addition to the international transactions - appellant submitted that its AE segment transactions constitutes only 59% of the total transactions however DRP has held that percentage at 70% without any basis - Held that:- Before us assessee has submitted that it is only 59% and not 70%. The same facts were also put before ld. DRP vide letter dated 16th May 2011 placed at Page No.804 of the Paper Book. In view of the above facts to verify this factual matter as principal has already been accepted by ld. TPO on direction of DRP we set aside this matter to the file of ld. TPO to work out the correct adjustment after verification.
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