The Tax Publishers2019 TaxPub(DT) 4701 (Del-Trib)

INCOME TAX ACT, 1961

Section 92C

Low turnover could not be a criteria to exclude Cosmic Global Limited (Seg.) being otherwise functionally comparable with that of assessee.

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

Assessee rendered back office support services to its AE abroad. TPO considered Cosmic Global Ltd. (Seg.) as comparable to assessee's case. Assessee contended that accounts BPO segment of said company, though comparable with assessee's nature of activity, had a small turnover of less than Rs. 1 crore as against assessee's whopping turnover of several crores of rupees. Held: Low turnover could not be a criteria to exclude Cosmic Global Limited (Seg.) being otherwise functionally comparable with that of assessee.

Followed: Chry Capital Investment Advisors (I) (P) Ltd. v. Dy. CIT (2015) 232 Taxman 20 (Del).

REFERRED :

FAVOUR : Against the assessee.

A.Y. : 2009-10

INCOME TAX ACT, 1961

Section 92C

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