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| The Tax Publishers2020 TaxPub(DT) 3838 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Excel Infoways Limited which was in the process of closing down its ITES segment and also because of factum of fluctuating margins, could not be selected as functionally comparable to assessee engaged in ITES.
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Transfer pricing - Determination of ALP - Selection of comparables - Widely fluctuating margins and diminishing revenue trend
Assessee rendered IT and Quality Assurance-' Support Services to its AE abroad. TPO considered Excel Infoways as comparable to assessee's case. Held: Excel Infoways Limited which was in the process of closing down its ITES segment and also because of factum of fluctuating margins, could not be selected as functionally comparable to assessee.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 36(1)(va)
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