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2020 (3) TMI 278 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Assessee provided software development services ; information technology enabled services and marketing support services to its associated enterprises on cost plus mark-up basis and availed of the management support services in the nature of legal, finance, human resource, information technology support and other support services from Avaya Singapore, thus companies functionally dissimilar with that of assessee need to be deselected from final list. Exclusion of government companies - Because of the absence of the profit motive and discharge of the social obligations, the Government companies stand on a different pedestal and are not good comparable to the entities like the assessee.
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