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The Tax PublishersITA Nos. 161 & 2307/Hyd/2018
2019 TaxPub(DT) 6529 (Hyd-Trib)INCOME TAX ACT, 1961
Section 92C
Hartron Communications Ltd. reported total revenue for the year to be at Rs. 33.12 crores as compared to preceding year where it was Rs. 21.38 crores showing an incease in overall revenue to the extent of 154.8% over the last year, therefore, it had to be excluded from set of comparables on account of exceptional year of performance, i.e., peculiar circumstances filter.
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Transfer pricing - Determination of ALP - Selection of comparables - Peculiar circumstances filter
Assessee rendered IT-enabled services to its AE abroad. TPO considered Hartron Communications Ltd. as comparable to assessee's case.Held: Hartron Communications Ltd. reported total revenue for the year to be at Rs. 33.12 crores as compared to preceding year where it was Rs. 21.38 crores showing an incease in overall revenue to the extent of 154.8% over the last year, therefore, it had to be excluded from set of comparables on account of exceptional year of performance, i.e., peculiar circumstances filter.
Followed:S&P Capital IQ India (P) Ltd. v. Dy. CIT (2019) 55 CCH 449 (Hyd-Trib) : 2016 TaxPub(DT) 3892 (Hyd-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14 & 2014-15
INCOME TAX ACT, 1961
Section 92C
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