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2023 (10) TMI 1132 - AT - Income TaxTP Adjustment - exclusion of Eclerx Services Limited from the set of comparable companies while determining Arm’s Length Price (ALP) - HELD THAT:- Assessee is rendering back office support service to its AE. There is no change in the services performed by the assessee right from the AY 2007-08 onwards. We find that this Tribunal in assessee’s own case for AY 2007-08 [2017 (1) TMI 1546 - ITAT DELHI] had excluded Eclerx from the list of comparable companies as functionally not comparable with the assessee. Hence, we direct the Ld. AO to exclude Eclerx Service Limited from the final list of comparables while determining the ALP of International Transactions of the assessee. Accordingly, Ground raised by the assessee is allowed.
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