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2021 (9) TMI 1445 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- We direct exclusion of Persistent Systems Ltd., Larsen & Toubro Infotech Ltd. and Infosys Ltd. & Infobeans Technologies Ltd. from the final list of comparables. We restore I2T2 India Limited, Evoke Technologies Limited and Melstar Information Technologies Limited to the file of AO/TPO for examining it afresh. Working capital adjustment - We find merit in the submissions made by Ld. A.R. Accordingly, we restore this issue to the file of AO/TPO with the direction to grant working capital adjustment. Transfer pricing adjustment should be restricted to the value of international transactions only - There is merit in the said contention as the whole purpose of transfer pricing exercise is to determine the Arms length price of international transactions. Accordingly we direct the AO/TPO to restrict the transfer pricing adjustment to the value of international transactions only.
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