The Tax Publishers2021 TaxPub(DT) 2159 (Bang-Trib)

INCOME TAX ACT, 1961

Section 92C

Larsen and Toubro Infotech Ltd. having high turnover of more than Rs. 200 crores deserved to be excluded from set of comparables by applying an upper turnover limit.

Transfer pricing - Determination of ALP - Selection of comparables - Higher turnover

Assessee rendered software development services to its AE abroad. TPO considered Larsen and Toubro Infotech Ltd. as comparable to assessee's case. Held: Larsen and Toubro Infotech Ltd. having high turnover of more than Rs. 200 crores deserved to be excluded from set of comparables by applying an upper turnover limit.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2010-11


INCOME TAX ACT, 1961

Section 92C

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