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| The Tax Publishers2019 TaxPub(DT) 6649 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Where TPO considered Apollo Healthstreet ltd., Asit C Mehta Financial Services Ltd. and Informed Technologies Ltd. as comparables to assessee's case by applying related party transaction *RPT) filter of 25%, matter was referred back to TPO for fresh decision by applying RPT filter of 15%.
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Transfer pricing - Determination of ALp - Selection of comparables - RPT filter
Assessee rendered IT enabled services to AE aboad. TPO considered Apollo Healthstreet ltd., Asit C Mehta Financial Services Ltd. and Informed Technologies Ltd. as comparables to assessee's case by applying related party transaction *RPT) filter of 25%.Held: Matter was referred back to TPO for fresh decision by applying RPT filter of 15%.
REFERRED : Poll to Win India Pvt. Ltd. v. Dy. CIT IT(TP)A No. 1053/Bang/2011, Tesco Hindustan Services Centers Pvt. Ltd. v. Dy. CIT ITA No. 1285/Bang/2011, Magma Design Automation India Pvt. Ltd. v. Asstt. CIT ITA No. 1241/Bang/2011 and First Advantage Offshore Services Pvt. Ltd. v. Dy. CIT ITA No. 1086/Bang/2011.
FAVOUR : Matter remanded.
A.Y. : 2006-07
INCOME TAX ACT, 1961
Section 92C
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