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2017 (12) TMI 1728 - AT - Income TaxTP Adjustment - Comparable selection - functional similarity - HELD THAT:- The assessee is a subsidiary of ADC Telecommunications Inc., USA and is engaged in the provision of software development services and IT Enabled Services to its AEs thus companies functionally dissimilar with that of assessee. Application of RPT filter at 25% of turnover - Assessee could not controvert the submissions of the Departmental Representative for Revenue that various coordinate benches of this Tribunal have been consistently following application of RPT filter at 25% of turnover - we reject the assessee's claim for exclusion of Aditya Birla Minacs Worldwide Limited, from the list of comparables and consequently uphold inclusion of this company ‘Aditya Birla’ by the authorities below in the final set of comparables.
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