9911796707
TMI Blog2017 (5) TMI 849X X X X Extracts X X X X X X X X Extracts X X X X ..... ities. 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 committed any error in holding that TCS is not an appropriate comparable as far as determining of the arms length price of international transactions involving the Assessee is concerned. No substantial question of law - ITA 94/2017 - ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... rned counsel for the Revenue, confines the challenge to the exclusion of one comparable i.e., TCS E-Serve Ltd. ( TCS ). She explains that as regards the exclusion of two other comparables, namely, Infosys BPO Ltd. and E-Clerx Services Pvt. Ltd. ( ECS ), this Court has in its order dated 5th August, 2016 in PCIT-01 v. Actis Glboal Services Pvt. Ltd. (ITA No. 417/2016) upheld the exclusion of those ..... X X X X Extracts X X X X X X X X Extracts X X X X ..... CS as comparable was that the segmental turnover data was not available. The ITAT observed that it was not known as to what extent the turnover of TCS was attributable to transfer processing and which portion to technical service . She submitted that the said information was in fact available as set out elsewhere in the impugned order. TCS's transfer processing income was ₹ 1,35,94, ..... X X X X Extracts X X X X X X X X Extracts X X X X
|
