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2019 (11) TMI 505 - AT - Income TaxTP Adjustment - Comparable selection - HELD THAT:- Assessee-company was incorporated as 100% export oriented unit under STPI of India Scheme at Bangalore, engaged in the products and works essentially in the nature of application acceleration solutions, management of congested Networks links and provides IT enabled services in the nature of order processing services technical support services to its Associated Enterprises thus companies functionally dissimilar with that of assessee need to be deselected. We restore the disputed issue to the file of the TPO for fresh examination and direct the TPO to include M/s.Akshay Software Technologies Ltd. and M/s.Spry Resources India Pvt. Ltd. as comparable in the final list of comparables for determination of ALP. The ld. AR restricted his arguments to exclusion and inclusion of comparable only. Accordingly, we allow the grounds of appeal of the assessee for statistical purposes.
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