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2020 (3) TMI 243 - AT - Income TaxTP Adjustment - exclusion of comparables relying on the additional ground of appeal of Turnover Criteria - HELD THAT:- Companies functionally dissimilar with that of assessee company as engaged primarily in rendering Software Development Research and Development Services to its Associated Enterprise (AE) M.S.Corp need to be deselected from final list. Companies functionally not comparable as the turnover is more than 500 times of the assessee turnover. Direct the TPO to grant the Working Capital and risk profile Adjustment after examining the facts and profiles of comparables.
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