Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (9) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (9) TMI 1155 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee is into services rendered under the title “Technical Support Services” and “Research and Development Services”. Both these services have been clubbed together as “Software Development Services” segment for bench marking.The assessee adopted TNM method as most appropriate method and Operating Profit/Operating Cost as Profit level indicator (PLI). We direct the AO/TPO to apply the upper turnover filter and exclude comparable companies, which are having turnover of more than ₹ 200/- crores. Companies functionally dissimilar with that of assessee need to be deselected from final list.
|