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2017 (5) TMI 1563 - AT - Income TaxTransfer pricing addition - comparable selection criteria - functional similarity - Held that:- Assessee is a resident company engaged in the business of providing IT enabled services such as data processing, customization of electronic data, back-office operations and acting as a support centre to provide research, analysis and information to various McKinsey and other corporate entities across the globe,thus companies functionally dissimilar with that of assessee need to be deselected from final list. Whether gains losses arising out of foreign exchange fluctuation while computing operating margins of the comparable companies shall be considered as part of operating profit or losses? - Held that:- As decided in assessee's own case foreign exchange gain or loss shall form the part of the operating margin of the assessee. Inter company receivable arising from the provisions of research and information services - whether constitute a separate international transactions under provisions of section 92B? - Held that:- As discussed earlier, this issue is squarely covered against the assessee in its own case for assessment year 11 – 12 [2017 (5) TMI 830 - ITAT DELHI] Intercompany receivables arising from provision of services do constitute a separate international transaction under section 92B of the act.
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