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TMI Blog2014 (7) TMI 1233X X X X Extracts X X X X X X X X Extracts X X X X ..... yan Jyoti Sengupta) This appeal is sought to be preferred and admitted by the Revenue against the judgment and order dated 24.10.2013 passed by the learned Tribunal in I.T.A.No.1154/Hyderabad/2011 in relation to the assessment year 2005-06, on the following suggested questions of law: 1. Whether, on the facts and the circumstances of the case, the Tribunal is justified in rejecting the comparab ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... s profit level indicator? We have heard Mr. J.V.Prasad, learned Standing Counsel for the Revenue and gone through the impugned judgment and order. He says that the learned Tribunal is wrong in concluding that M/s.Vishal Information Technology Limited cannot be considered as a comparable case on the ground mentioned therein ignoring the fact that Indian Transfer Pricing Regulations prescribe arith ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... yee's cost to total cost ratio is worked out at 2% as compared to the industry average of 30 to 40%. The assessee's employee's cost to total cost ratio is worked out at 47%. Since the employee's cost form major cost base in ITES service industries, the low ratio of comparables implies that it would not be providing services by employing its own sources. Being so, the assessee is not alike to M/s.V ..... X X X X Extracts X X X X X X X X Extracts X X X X
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