The Tax Publishers2020 TaxPub(DT) 3279 (Del-Trib)

INCOME TAX ACT, 1961

Section 92C

Because of extraordinary events such as restructuring that took place in the period under consideration, Infosys BPO Limited, and TCS E-Serve Limited were not good comparables to assessee's case.

Transfer pricing - Determination of ALP - Selection of comparables - Extraordinary events

Assessee rendered IT enabled services to its AE abroad. TPO considered TCS E Serve Ltd. and Infosys BPO Ltd. as comparable to assessee's case. Held: Because of extraordinary events such as restructuring that took place in the period under consideration, Infosys BPO Limited, and CS E-Serve Limited were not good comparables to assessee's case.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. :


INCOME TAX ACT, 1961

Section 92C

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