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| The Tax Publishers2020 TaxPub(DT) 2946 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Related party transactions in case of HCL Comnet Systems and Services Ltd. as a percentage of operating revenue worked out to 28.19% thereby exceeding threshold limit of 25% fixed by TPO. Also the company had a different accounting year ending which was 30th June and, therefore, it could not be taken as comparable to assessee's (engaged in BPO services).
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Transfer pricing - Determination of ALP - Selection of comparables - Failing of RPT filter
Assessee rendered business process outsourcing (BPO) services to AE abroad. TPO considered HCL Comnet Systems and Services Ltd. as comparable to assessee's case. Held: Related party transactions (RPT) of HCL Systems and Services Ltd. as a percentage of operating revenue worked out to 28.19% thereby exceeding threshold limit of 25% fixed by TPO. Also the company had a different accounting year ending which was 30th June. Hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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