Home Case Index All Cases Income Tax Income Tax + HC Income Tax - 2023 (9) TMI HC This
Forgot password New User/ Regiser ⇒ Register to get Live Demo
2023 (9) TMI 1167 - HC - Income TaxTreatment of foreign exchange gain/loss by categorizing it as operating income/ operating loss - HELD THAT: As appellant cannot but accept that it stands covered against the appellant/revenue by a decision titled Pr. Commissioner of Income Tax-3 v. Fiserv India Pvt. Ltd. [2016 (1) TMI 1276 - DELHI HIGH COURT] TP Adjustment - comparable selection - Tribunal excluding two comparables i.e., Wipro Technologies Services Ltd. and Infosys Ltd - HELD THAT:- As it cannot be disputed the fact that assessee is in the business of providing software development services. The two comparables i.e., Wipro Technologies Services Ltd. and Infosys Ltd. are in the business of not only software development services but also in the sale of software products. Clearly, since according to the Tribunal the segmental information was not available, the comparables were ordered to be excluded. We are of the opinion that there is no error in the approach adopted by the Tribunal, which is otherwise in line with the view taken by the coordinate bench.
|