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2018 (4) TMI 429 - AT - Income TaxTPA - comparable selection criteria - Held that:- Assessee is classified into software development segments, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Risk adjustment qua comparables and the assessee - Held that:- It is for the assessee to demonstrate as to how the assessee who is a captive service provider to its AE has more risk in comparison to the other comparables retained by the Tribunal. Since no details and working has been provided, therefore, we do not deem it appropriate to grant any risk adjustment to the assessee. Accordingly this ground is rejected.
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