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2020 (10) TMI 1150 - HC - Income TaxTP Adjustment - comparable selection - excluding Celestial Labs Ltd., Infosys Technologies Ltd, KALS Information Systems Ltd., Tata Elxsi Ltd. Wipro Ltd and Lucid Software Ltd. - HELD THAT:- Issue with regard to functional similarity of the assessee has been examined in detail by the Tribunal. Therefore, we hold that the first substantial question of law framed by a bench of this court in fact, does not arise for consideration in the instant case. Transfer Pricing analysis and the risk adjustment - In second substantial question of law Tribunal has remitted the issue with regard to market risk adjustment to the Assessing Officer in the light of the decision, which have been cited in the order of the Tribunal. We deem it appropriate to modify the aforesaid directions contained in the order of the Tribunal and direct the Assessing Officer to determine the issue with regard to market risk adjustment afresh in accordance with law. Accordingly, the second substantial question of law is answered. Deduction u/s 10B - reimbursement of traveling and technical services charges incurred in foreign currency - The third and fourth substantial questions of law are against the revenue and are covered by the by decision of the Supreme Court in HCL TECHNOLOGIES LTD [2018 (5) TMI 357 - SUPREME COURT]
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