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2015 (9) TMI 1630 - ITAT BANGALOREAdjustment in the arm’s length price(ALP) of international transaction entered into by the Assessee with it’s Associated Enterprise (AE) u/s 92 - Assessee provided Software Development Services to its AE - Comparable selection - Held that:- Assessee providing IT Software development Services thus companies functionally dissimilar with that of assessee need to be deselected from final list. Excluding Comparable from the list of comparable chosen by the TPO, the arithmetic mean of profit margin of the remaining comparable is directed to be reworked by the TPO/AO after allowing +/- 5% adjustment, if permissible, u/s.92C(2) of the Act. None of the other grounds are adjudicated except comparability of companies chosen by the Assessee, as the exclusion of comparable companies chosen by TPO and confirmed by the DRP would itself result in the price charged in the international transaction to be one at Arm’s Length.
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