The Tax Publishers2020 TaxPub(DT) 2970 (Del-Trib)

INCOME TAX ACT, 1961

Section 92C

HCL Technologies Ltd. had 71% related party transactions (RPT) and HP Global Soft Ltd. had 87% RPT and thus both the companies not meeting 25% RPT filter applied by TPO could not be taken as comparables to assessee's case.

Transfer pricing - Determination of ALP - Selection of comparables - Failing of RPT filter

Assessee rendered IT enabled back office support services to its AE abroad. TPO considered HCL Technologies Ltd. and HP Globalsoft Ltd. as comparables to assessee's case.Held: HCL Technologies Ltd. had 71% related party transactions (RPT) and HP Global Soft Ltd. had 87% RPT and thus both the companies not meeting 25% RPT filter applied by TPO could not be taken as comparables to assessee's case.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2004-05

INCOME TAX ACT, 1961

Section 92C

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