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2019 (3) TMI 144 - AT - Income TaxTP Adjustment - selection of comparable - functional similarity - Importance of Brand value in selection of comparable - good comparable - HELD THAT:- With respect to Kerala Travels Interserve Ltd., we have carefully perused its financial statements and we find the main revenue is from different activities and not from the tour operations. Therefore, Kerala Travels Interserve Ltd., cannot be held to be the good comparable and we accordingly direct the AO/TPO to exclude this company from the list of comparables. With regard to Cox & Kings it is involved in different activities besides tour operation and has its own brand value. Therefore, it cannot be held to be a good comparable for determination of the ALP for the international transactions. We accordingly direct the AO/TPO to exclude this company from the list of comparables while determining the ALP for international transactions. Accordingly, we direct the AO/TPO to exclude these two comparables and recompute the ALP in terms indicated above after setting aside the assessment order in this regard.
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