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2019 (7) TMI 311 - HC - Income TaxTP adjustment - exclusion of the company E-Infochips Bangalore Ltd. in the final set of comparables for the purposes of the transfer pricing (TP) exercise - HELD THAT:- What appears to have weighed with the ITAT in agreeing with the DRP to exclude the said comparable is its wide ranging clientele. As found to be providing hi-tech engineering consulting and product innovation services, not just to software developers but also to other sectors like aerospace, defence, healthcare, media and broadcast, medical devices, security and surveillance etc. The exclusion of the said comparable cannot, therefore, be said to be unjustified. Infinite Data Systems Private Limited exclusion ITAT has based its conclusions on a detailed analysis of the profile of the said comparable vis-a-vis the Assessee. Choice of comparables for the TP analysis has been explained by this Court in Rampgreen Solutions Pvt. Ltd. v. CIT, [2015 (8) TMI 931 - DELHI HIGH COURT]. Even otherwise, the Court is not persuaded that the impugned order of the ITAT suffers from any serious error in law or gives rise to any substantial question of law.
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