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2019 (1) TMI 1326 - AT - Income TaxTPA - international transactions entered into with its associated enterprises in respect of provision of IT enabled and marketing support services - Comparable selection - employees cost to sales ratio analysis - Held that:- As directed in assessment year 2012-13 to verify the claim of the assessee whether in case employees cost to sales ratio was less than 25%, then both the concerns [Ninestar Information Technologies Limited and Universal Print Systems Limited have to be excluded from final set of comparables. So far as Excel Infoways Ltd. is concerned, the Tribunal has held that same is not comparable on account of its fluctuation margins. With regard to Universal Print Systems Ltd., it also needs verification and in case it is less than 25% then the said concern is not be included in the final list of comparables. Thus we restore the matter for verification to the Assessing Officer to adjudicate this issue afresh after providing reasonable opportunity of hearing to the assessee. Thus, ground raised in appeal by assessee is allowed for statistical purposes.
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