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2019 (9) TMI 558 - HC - Income TaxTP Adjustment - comparable selection - Tribunal excluded M/s Accentia Technologies Limited, M/s TCS E-Serve Ltd. and M/s TCS E-Serve International Ltd. from comparables for determining the ALP - HELD THAT:- Revenue was unable to demonstrate that the order of the Tribunal suffers from any illegality or perversity as it had failed to consider or appreciate any relevant circumstances for excluding these three comparables, namely, M/s. Accentia Technologies Ltd., M/s. TCS E-Serve Ltd. and Ms. TCS E-Serve International Ltd. for determining the ALP as functionally dissimilar with that of assessee. It cannot be held that the aforesaid findings recorded by the Tribunal in the appeal warrant any interference by this Court.
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