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2018 (10) TMI 1361 - AT - Income TaxTransfer pricing adjustment - Comparable selection - functinal similarity - Held that:- The assessee is providing software development services to its AEs thus concerns as not functionally comparables need to be excluded from the final set of comparables. Not allowing of working capital adjustment - Held that:- AR for the assessee fairly submitted that in case the two concerns i.e. Bodhtree Consulting Ltd. and Kals Information Systems Ltd. are excluded from the final set of comparables and working capital adjustment is allowed to the assessee, then the transactions with its AEs would be at arm’s length price and no other issue needs to be adjudicated. Accordingly, we do not address the non-inclusion/exclusion of PSI Data Systems Ltd. in the final list of concerns.
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