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2023 (12) TMI 868 - ITAT MUMBAITP Adjustment - Comparable selection - Excluding two comparable companies M/s Exclerx Services Ltd. and M/s Vishal Information Technologies Ltd. from the set of comparables for benchmarking assessee’s international transaction of provision of back office support services - HELD THAT:- Vishal Information Ld. Outsourced significant portion of its business whereas assessee company entirely carried out its business without outsourcing therefore we justify the decision of ld. CIT(A) in excluding this company from the list of comparable. In respect of Eclerx Service Ltd. we find that the function of that company was not similar to the assessee company therefore we do not find any merit in the ground of appeal of the Revenue. No infirmity in the decision of ld. CIT(A). Accordingly, ground no. 1 of the appeal of the revenue is dismissed. M/s R System International Ltd. company was functionally comparable with the assessee company and consistently accepted as a comparable for the earlier years by the lower authorities, we don’t find any reason to interfere in the decision of ld. CIT(A) for including this company in the set of comparable. Therefore this ground of appeal of the revenue is dismissed.
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