The Tax Publishers2019 TaxPub(DT) 8379 (Del-Trib)

INCOME TAX ACT, 1961

Section 92C

When financial results of M/s. R. System International Ltd. were available in public domain and had been recasted on the basis of audited quarterly result and audited financial results could be duly considered as comparable to assessee's case.

Transfer pricing - Determination of ALP - Selection of comparables - Rejection on the ground of different financial year ending--Quarterly results available in public domain

Assessee rendered IT-enabled services to AE abroad. TPO considered M/s. R. system International ltd. as not comparable to assessee's case on the ground that this company was having different financial year ending.Held: When financial results of M/s. R.System International Ltd. were available in public domain and had been recasted on the basis of audited quarterly result and audited financial results could be duly considered as comparable to assessee's case.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2011-12


INCOME TAX ACT, 1961

Section 92C

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