Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2016 (4) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2016 (4) TMI 1250 - AT - Income TaxTPA - selection of comparable - Held that:- As assessee company engaged in the business of software development. The company provides software development and allied services in the area of Mail Plant, Web Mail platform and internet related software. This company in Hyderabad is registered as a 100% EoU under STPI Scheme of Govt. of India. This company is one of the group companies of United Online, US, thus companies functionally different with that of assessee need to de-selected from final list of comparability. We therefore direct the Assessing Officer/TPO to determine the ALP keeping in view our directions given hereinabove and if on such determination the price charged by the assessee for its international transaction is found to be within the arms length then no adjustment is required to be made.
|