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2021 (3) TMI 877 - ITAT BANGALORETP Adjustment - comparable selection - HELD THAT:- Assessee stated to be having following functions under software development service segment: Arriba supplies network, platform/infrastructure, Arriba sourcing, Arriba buyer, technical solution centres. Under ITES segment assessee provides technical support services, Data enrichment services, strategic sales and delivery support shared services. Law laid doen in GENISYS INTEGRATING SYSTEMS (INDIA) (P.) LTD. VERSUS DEPUTY COMMISSIONER OF INCOME-TAX [2011 (8) TMI 952 - ITAT BANGALORE] has to be followed. We uphold exclusion of Infosys Technologies Ltd., Kals Information Systems Ltd. and Tata Elxsi Ltd., from the final list of comparable under software development service segment. Under ITES segment exclusion of Eclerx services Ltd. and Infosys BPO Ltd. are upheld. Accordingly these grounds raised by revenue stands dismissed. Deduction u/s 10A - HELD THAT:- CIT(A) directed Ld. AO to compute the deduction under section 10A in accordance with the decision of Hon'ble Karnataka High Court in case of Tata Elxsi Ltd.[2011 (8) TMI 782 - KARNATAKA HIGH COURT]. We do not find any infirmity in such view taken by Ld. CIT(A) and the same is upheld.
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