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2020 (10) TMI 664 - AT - Income TaxTP Adjustment - Comparable selection - benchmarking of international transaction of provision of Ancillary Management Support Services by providing marketing support services to the Associated Enterprises - HELD THAT:- Apitco Ltd. and GPCL rejected on the ground that Government companies are not comparable to business concerns. See PHILIP MORRIS SERVICES INDIA SA [2019 (1) TMI 653 - DELHI HIGH COURT]. Exclusion of TSR Darashaw Ltd. as no segmental information was available in respect of the different segments operated by the company. HSCC (India) Ltd. - assessee claims that because of difference in provisions of doubtful debts, the margins have been incorrectly computed at 18.32% whereas the correct margin is 8.96% - We direct the Assessing Officer/TPO to re-compute the margins of the said concern i.e. HSCC (India) Ltd. by including provision of doubtful debts as an operating item and re-compute the mean margin of assessee. Specturm Business Solution Ltd. - Because of the similarity of functions being performed by both the companies, we direct the inclusion of Specturm Business Solution Ltd. in the final list of comparables.
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