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2021 (10) TMI 1298 - AT - Income TaxTP Adjustment - comparable selection - functional dissimilarity - HELD THAT:- Assessee is doing business of ITes segment wherein major work is of analytical support and functions with software services as only incidental to and not independent of such analytical functions, thus companies functionally dissimilar with that of assessee need to be deselected. Also if an extraordinary event has taken place by way of amalgamation that company cannot be considered as a comparable one - See BRINTONS CARPETS ASIA PVT. LTD.case [2019 (4) TMI 56 - ITAT PUNE] While making the selection of comparables, the turnover filter, has to be the basis for selection. A company having turnover of ₹ 11 crores cannot be compared with a company which is having turnover of ₹ 260 crores which is more than 23 times. See M/S. PENTAIR WATER INDIA PVT. LTD. [2016 (5) TMI 137 - BOMBAY HIGH COURT]
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