The Appellate Tribunal held that negative working capital ...

Appellate Tribunal Excludes Multiple Companies from Comparables in Transfer Pricing Case for Captive Service Provider.

June 28, 2024

Case Laws Income Tax AT

The Appellate Tribunal held that negative working capital adjustment cannot be made for a captive service provider. L&T Infotech Ltd. and Infosys Ltd. were excluded from comparables as the assessee is a captive service provider compensated on a cost+mark-up basis. Persistent Systems Ltd. was excluded due to lack of segmental details. Infobeans Technologies Ltd. was found not functionally comparable. Tata Elxsi Ltd. was excluded as it generates revenue from product sales. Mindtree Ltd. & Nihilent Ltd. lacked segmental financials. Cygnet Infotech Pvt. Ltd. was excluded for not being a captive service provider. Cybage Software Pvt. Ltd. was excluded due to diversified activities. Batchmaster Software Pvt. Ltd. was remanded for further verification. The issue of deduction u/s. 10AA and interest levy u/s. 234A, 234B, 234C requires verification by the assessing officer based on evidence provided by the assessee.

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The Appellate Tribunal held that negative working capital ...

Appellate Tribunal Excludes Multiple Companies from Comparables in Transfer Pricing Case for Captive Service Provider.

June 28, 2024

Case Laws Income Tax AT

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