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2017 (10) TMI 687 - AT - Income TaxTPA - ALP determination - Comparable selection procedure - Held that:- Stryker Technology started its business from October 1, 2006 as a global technology centre for the Stryker Group in India. The taxpayer operates as a technology support centre for the group and provides Computer Aided Designing (CAD) / engineering, contract software development, and IT Enabled back office support services to the Stryker Group. According to TP report, Stryker Technology has been characterized as a routine CAD / engineering contract software development and IT enabled back office support services provider and stated to use all the valuable intellectual property rights (know-how, copyrights etc.) and other commercial or marketing intangibles (brand names, trademarks etc.) owned by the Group. Transactional Net Margin Method (TNMM) used by the assessee for benchmarking its international transaction as most appropriate method has been accepted by the TPO/DRP. Thus Companies functionally dissimilar with that of assessee need to be deselected from final list of comparable. Adding back the amount of Rent equalization reserve to the book profits of the Appellant, declared under section 115JB - Held that:- AO has rightly added back the rent acquisition reserve debited to profit & loss account while computing the book profit for the purpose of section 115JB of the Act
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