The Tax Publishers2020 TaxPub(DT) 0642 (Ahd-Trib)

INCOME TAX ACT, 1961

Section 92C

Financial statement of Rolta India Ltd. was for the entire group and consolidated financial statements could not be compared with assessee engaged in engineering services.

Transfer pricing - Determination of ALP - Selection of comparables - Consolidated financial statements

Assessee rendered engineering services to its AE abroad. TPO considered Rolta India as comparable to assessee's case.Held: Financial statement of Rolta India Ltd. was for the entire group and consolidated financial statements could not be compared with assessee.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2006-07


INCOME TAX ACT, 1961

Section 92C

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