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2024 (2) TMI 273 - AT - Income TaxTP Adjustment - comparable selection - upper turnover filter - assessee submits that the turnover of the assessee is only Rs. 124 Crores during the relevant previous year, hence, companies having turnover of more than Rs. 200 Crores needs to be excluded from the comparable list while calculating the ALP of the said international transaction - HELD THAT:- In view of the above order of the Tribunal in assessee’s own case for Assessment Year 2015- 16 [2022 (10) TMI 1225 - ITAT BANGALORE], we restore the matter to the TPO and direct him to adopt upper turnover filter of Rs. 200 Crores. The TPO is directed to exclude from the comparable list companies whose turnover is exceeding 200 Crores and accordingly recalculate the ALP of the international transaction in the software development segment. It is ordered accordingly.
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