Home Case Index All Cases Income Tax Income Tax + AT Income Tax - 2020 (2) TMI AT This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2020 (2) TMI 972 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee is engaged in providing consultancy/ information technology enabled services (ITeS) to its foreign Associate Enterprises (AE), thus companies functionally dissimilar with that of assessee need to be deselected from final list. Thus we direct the AO/TPO to exclude Infosys BPO Ltd., Accentia Technology Ltd., Acropetal Technology Ltd. and Eclerx Services Ltd. and include Datamatics Financial Services Ltd. in the final set of comparable and recompute the ALP of ITeS support services with its AE Exclusion of Eclerx from final set of comparable on functional dissimilarity. Therefore, following the principle of consistency, the AO/TPO is directed to exclude Eclerx from final set of comparable and recompute the ALP of its international transaction with AE.
|