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2023 (10) TMI 1193 - AT - Income TaxTP Adjustment - comparable selection - HELD THAT:- Accentia Technologies Ltd. As provided KPO services and, therefore, it is not comparable with the assessee company, which is carrying on BPO activities. TCS E-Serve International Ltd' s annual report of the company does not provide any segmental information related to ITES as well as software development services. The company also owns intangible of substantial amount and is benefitted usually by the Tata Brand. The company is also making appellant for use of such brand. Therefore this aspect also makes this comparable is inappropriate and therefore we order to exclude this comparable. TCS E Serve Limited.nvolved in transaction processing and technology services. It carries on business of providing technology service such as software testing, verification and validation. It is also developed a software such as transport management software therefore functionally this company is dissimilar to the assessee company. It also owns huge intangible and use of 'Tata Brand, which has definitely benefited this comparable, it is directed to be excluded." No valid reason to interfere with the findings of the ld. CIT (Appeals) in excluding the above comparables from the final list of comparable - Appeal of the Revenue is dismissed.
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