9911796707
TMI Blog2019 (6) TMI 1396X X X X Extracts X X X X X X X X Extracts X X X X ..... contested in this appeal relate to TP adjustments made by the TPO and disallowance of bad debts claimed by the assessee. 2. At the time of hearing, the assessee did not press ground No.14 relating to disallowance of bad debts due to smallness of the amount. Accordingly the said ground is dismissed as not pressed. 3. Ground Nos.15 and 16 relates to interest charged u/s 234B and 234C of the Income-tax Act 1961 ('the Act'). Both are consequential in nature and hence they do not require any adjudication. 4. The other grounds relate to transfer pricing adjustment. 5. The assessee is a part of Communication group of companies. It is engaged in the business of rendering media analysis services to its associates enterprises. The communicati ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... ce rendered in the case of Northern Operating Services IT(TP)A No.101/Bang/2016, more particularly paragraph 18 of the order thereof, the ld AR submitted that high turnover companies cannot be compared with the low turnover companies. 8. The ld AR further submitted that the ld DRP has confirmed inclusion of Universal Print Systems Ltd., and BNR Udyog Ltd. The coordinate bench in the case of Mobility Infotech India Pvt. Ltd., (2018) 97 taxmann.com 2 has restored both these comparable companies to the file of AO/TPO for examining the same afresh by duly considering the contentions of the company. 9. The ld DR on the contrary supported the order passed by the AO. 10. We have heard the rival contentions on this issue and perused the recor ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... panies. With regard to Universal Print Systems Ltd (Seg. BPO), the assessee has contended in the above said case that it is functionally different and it fails on RPT filter also. With regard to BNR Udyog Ltd (Seg - Medical Transcription), the assessee has contended in the above said case that it is functionally different, fails on RPT filter and error in margin computation. Hence the co-ordinate bench has restored both the comparables in the case of Mobility Infotech India P Ltd to the file of AO/TPO and for that purpose, the co-ordinate bench has taken support of decisions rendered in the case of CGI Information Systems and Management Consultants (P) Ltd (2018)(94 taxmann.com 97 (Bang. Trib) and Indegene P Ltd (2017)(85 taxmann.com 60)(Ba ..... X X X X Extracts X X X X X X X X Extracts X X X X
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