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2017 (11) TMI 1724 - AT - Income TaxTPA - comparable selection - functinal comparability - Held that:- The assessee is a company incorporated on 19.03.2004 and is wholly owned subsidiary of Omniglobe International LLC, USA, which is engaged in the provision of BPO/Data Processing Services to its AE. It also provides IT Enabled services relating to phone activation and local number portability to various clients for and on behalf of its parent company, thus companies functionally dissimilar with that of assessee need to deselected from final list. As three comparables [Accentia Technologies Ltd., TCS E-Serve Ltd. and Infosys BPO Ltd.] are excluded from the list of comparables, the average margin of the OP/OC of the comparables comes to 11.60% as against 8.63% margin declared by the assessee and the assessee falls within +/-5%. The TPO is accordingly directed to verify the same and pass appropriate order. The grounds raised by the assessee are accordingly partly allowed.
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