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2011 (6) TMI 398 - AT - Income Tax
Determination of arm's length price - Operating expenditure - payment of lease rent - expenditure of the parent company has been shifted to the assessee. - held that:- transfer pricing adjustment is required to be made in respect of the rent, while working out the arm's length PLI. At the same time, it is also held that suitable adjustment has to be made to such PLI in respect of idle capacity. - matter restored to the file of the AO.
Rejection of comparable of six companies identified by TPO - held that:- it is seen that none of the comparables selected by the TPO is shown to have the same business of voice based BPO as in the case of the assessee. - Decided against the revenue.