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2019 (2) TMI 2085 - AT - Income TaxTP Adjustment - comparable selection - Assessee as Providing ITES services - HELD THAT:- Accentia Technologies Ltd., and Acropetal Technologies Ltd., should be excluded from the list of comparable companies as functionally dissimilar. ICRA Online Ltd. is concerned, the RPT in the case ICRA Online Ltd., needs to be verified by the TPO and if the RPT is more than 15% of the total revenue of this company then the same should be excluded. Jeevan Scientific Technology is concerned, the TPO is directed to examine the comparability of this company as was directed by the Tribunal in the case of Swiss Re Shared Services India Pvt. Ltd [2016 (7) TMI 1359 - ITAT BANGALORE]. TPO is directed to compute the ALP as per the directions given above after affording opportunity of being heard to the assessee.
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