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2016 (8) TMI 1365 - AT - Income TaxTransfer Pricing related grounds - Comparable specific - Held that:- Referring to business support services provided by the Appellant to its associated enterprise functional dissimilarity need to be seen to select comparability. Absence of any difference in facts having been pointed out by the ld. DR of the revenue, we direct the AO/TPO to exclude these three companies i.e. M/s Aptico Ltd., M/s Global Procurement Consultants Ltd., and M/s TSR Darashaw Ltd. from the list of final comparables and since, the average profit of the remaining three comparable i.e. M/s Cyber Media Research Ltd.,14.85%, M/s HCCA Business Services Pvt. Ltd., 20.05% and M/s Quadrant Communications Ltd., 1.11% is around 16% which is within += 5% range of the assessee’s profit margin of 12.06%, no TP adjustment is required to be made. We hold accordingly.
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