Tag: comparable
Non profit company not a comparable for Transfer Pricing. ITAT directed AO to exclude it from the list of comparables to benchmark international transaction. ABCAUS Case Law Citation:ABCAUS 3112 (2019) (08) ITAT The appellant assessee was is a subsidiary of the parent company which operated travel website under …
Capacity Utilization Adjustment in transfer pricing allowed for early years of operation where comparables had on average higher utilization ABCAUS Case Law Citation: ABCAUS 3062 (2019) (07) ITAT Important Case Laws Cited/relied upon by the parties: Global Vantedge (P) Ltd. Vs. DCIT E-Gain Communications Pvt. Ltd. 118 TTJ …
Exclusion inclusion of comparables to determine Arm’s Length Price (ALP) not necessarily give rise to purely legal or substantial questions of law – High Court ABCAUS Case Law Citation: ABCAUS 2556 (2018) (10) HC Important Case Laws Cited/relied upon by the parties: Principal Commissioner of Income Tax v/s …
High Court upheld inclusion and exclusion of comparables by TPO based on filters of losses, declining sales, segment reporting employee cost etc. ABCAUS Case Law Citation: ABCAUS 2280 (2018) (04) HC The appellant assessee had filed the instant appeal under Section 260A of the Income Tax Act, 1961 …
Comparable company following calendar year for maintaining accounts can not be used in contrast to assessee following financial year ending 31st March despite functional similarities – ITAT Prelude: Chapter X of the Income Tax Act, 1961 (the Act) contains Special provisions relating to avoidance of Tax. Section 92 …
In a recent judgment, ITAT Delhi has held that Knowledge Process Outsourcing Services (KPO Services) provider could not be be considered as a comparable for benchmarking international transactions entered into by an entity rendering business process outsourcing (BPO) services including collections/call centre services and other back office support services for …