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2018 (12) TMI 1070 - AT - Income TaxTPA - difference in the arm’s length price of the international transaction of provision of software development services - comparable selection - Held that:- Assessee is engaged in the business of providing end-to-end business solutions in location Intelligence, which combines technology, data and services with domain expertise to enable an organization to measure, compare, visualize its business data thus companies functionally dissimilar with that of assessee need to be deselected from final list. After exclusion of four comparables Birla Soft India Ltd, Wipro Ltd, Larsen & Toubro Infotech Ltd and Tata Technologies Ltd the margin of the assessee comes within the range of +/- 5%. Since the operating profit margin of the assessee is within the plus minus 5% of the operating profit margin of the comparables, we do not find any reason why receivables should be considered separately for determining ALP. Interest has already been considered. Accordingly we hold that no interest can be imputed separately and additionally. We direct the Assessing Officer/TPO to delete the addition - decided in favour of assessee.
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