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2017 (9) TMI 1757 - AT - Income TaxTPA - comparable selection criteria - Held that:- As regards the employee cost filter is a proper criteria for selection of the comparable, we find that this Tribunal has taken a consistent view that the employee cost to the total cost is a relevant factor to decide the business model and functional profile of the comparable. Therefore, when the TPO has applied a filter for all the comparable companies then the same cannot be rejected for the purpose of including one company in the set of comparables. Deselection of companies dissimilar with that of assessee as pure software development services provider.
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