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2018 (1) TMI 388 - AT - Income TaxTPA - international transaction of the assessee pertaining to the provisions of EDS does not satisfy the arm’s length principle - comparable selection criteria - Held that:- Assessee is engaged in the business of providing engineering services, generating engineering drawings and providing other IT enabled services together referred to as “engineering related service” for offshore facilities. The primary business of SHI Korea encompasses shipbuilding, offshore floaters, digital devices for ships & construction and engineering services, thus companies functionally dissimilar with that of assessee need to be deselected from final list.
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