Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2014 (1) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2014 (1) TMI 890 - AT - Income TaxRejection of comparables - Adjustment in arm's length price - Exclusion of Wipro BPO Solutions The decision in M/s. HSBC Electronic Data Processing India Ltd. Versus Dy. Commissioner of Income-tax Circle 2(2), Hyderabad [2013 (9) TMI 485 - ITAT HYDERABAD] followed - The contentions of the assessee against the inclusion of this comparable are not accepted, and this company was included as one of the comparables on the reason that the assessee's turnover is equally high as that of Wipro BPO Solutions - the assessee's contention that profit margin worked out by the TPO is incorrect requires to be examined by the TPO/Assessing Officer the matter restored to the AO for fresh adjudication to examine the assessee's contentions on this aspect and accordingly decide the PLI of this comparable. Exclusion of Mercury Outsourcing Management Ltd and Transworks Information Services Ltd as comparables Held that:- The order of the CIT(A) is not elaborate - The nature of the related party transactions cannot be examined and the TPO's working is different from the assessee in the interests of justice the matter restored back to the AO to re-examine the functionality of the company afresh Decided in favour of Assessee.
|