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| The Tax Publishers2019 TaxPub(DT) 0820 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Where TPO considered Tismo Technology Solutions Ltd. as non-comparable to assessee's case on the ground of non-availability of financial data at the time of Transfer Pricing proceedings and assessee submitted that financial data was available on the capital in dataase and its margin calculation, matter was referred back to TPO for verification of financial that were available after applying relevant filters.
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Transfer pricing - Determination of ALP - Selection of comparables - Non-availability of financial data
Assessee rendered providing engineering and design services to its AE abroad. TPO considered Tismo Technology Solutions Ltd. as non-comparable to assessee's case on the ground of non-availability of financial data at the time of Transfer Pricing proceedings. Assessee submitted that financial data was available on the capital in dataase and its margin calculation. Held: In the interest of justice, matter was referred back to TPO for verification of financial that were available after applying relevant filters.
REFERRED :
FAVOUR : Matter remanded.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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