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2021 (9) TMI 1502 - AT - Income TaxTP Adjustment - provision of back-office support services/income received from ITES segment - comparable selection - HELD THAT:- Exclusion of Universal Print, TCS e-serve and Infosys BPO from the list of comparables and remand BNR Udyog Ld. AO/TPO to consider it afresh in light of the observations made by coordinate bench of this Tribunal reproduced hereinabove. Negative working capital computed by the Ld.TPO, without appreciating the fact that assessee is a captive service provider - We find that in the case of Software AG Bangalore Technologies (P.) Ltd. [2016 (3) TMI 1384 - ITAT BANGALORE] passed by this Tribunal, it has been held that negative working capital adjustment shall not be made in case of a captive service provider as there is no risk and it is compensated on a total cost plus basis.
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