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2021 (2) TMI 538 - AT - Income TaxTP Adjustment - Comparable selection - action of AO/TPO for selecting companies as comparables without considering their functions undertaken and picking the high margin companies by applying arbitrary filters - main contention of Ld. AR is that Eclerx Services Ltd. is functionally not comparable to the functions of assessee - HELD THAT:- There is no dispute regarding exclusion of Eclerx Services Ltd. by this Tribunal in assessee's own case in A.Y. 2011-12 [2020 (8) TMI 441 - ITAT PUNE] There is no dispute regarding exclusion of Eclerx Services Ltd. by this Tribunal in assessee's own case in A.Y. 2011-12 Eclerx Services Ltd. shall be excluded from the set of comparables and the AO/TPO is directed to determine the arm's length price for the purpose of benchmarking of international transactions in design engineering services segment. Thus, the final assessment order in this regard is set aside and the ground raised by the assessee are allowed.
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