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2017 (5) TMI 849 - DELHI HIGH COURT

2017 (5) TMI 849 - DELHI HIGH COURT - TMI - TPA - TCS as not an appropriate comparable - Held that:- The Court finds merit in the contention of Mr. Kamal Sawhney, learned counsel for the Respondent, that as far as profile of the Assessee was concerned, it was not involved in software development at all but only in BPO activities. This apart the size and scale of TCS's operations makes it an inapposite comparable vis-a-vis the Petitioner. - The Court is not convinced that the ITAT has committ .....

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ions. ITA No. 94/2017 2. This is an appeal by the Revenue under Section 260A of the Income Tax Act, 1961 against the order dated 29th July, 2016 passed by the Income Tax Appellate Tribunal ( ITAT ) in ITA No. 6175/Del/2015 for the Assessment Year 2011-12. 3. Although the Revenue has urged a question concerning the exclusion by the ITAT of the three comparables in determining the arms length price of international transactions involving the Respondent/Assessee, Ms. Lakshmi Gurung, learned counsel .....

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It is noted by the ITAT in the impugned order that TCS is involved both in transaction processing and technical services . The ITAT has referred to the decision of a Coordinate Bench of the ITAT in the case of Ameriprise India Pvt. Ltd. in ITA No. 7014/Del./2014 where, again, while determining the arms length price, TCS has been excluded as a comparable. 5. It is pointed out by learned counsel for the Respondent/Assessee that the order in Ameriprise India Pvt. Ltd. has been affirmed on 19th Octo .....

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