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| The Tax Publishers2020 TaxPub(DT) 4848 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Companies having turnover more than Rs. 200 crores upto Rs. 500 crores had to be regarded as one category and those companies could not be regarded as comparable with assessee-company having turnover of less than Rs. 200 crores.
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Transfer pricing - Determination of ALP - Selection of comparables - Relevance of turnover filter
Assessee rendered software development servcies to its AE abroad. TPO considered Larsen and Toubro Infotech Ltd.; Mindtree Ltd. (Seg.); Persistent Systems Ltd., Tech Mahindra Ltd. (Seg.) as comparables to assessee's case. Assessee submitted that turnover of assessee company during the year was Rs. 40 crores and hence, it fell under the category of companies having turnover in the range of Rupees one crore to Rs. 200 crores. However, turnover of above said companies was more than Rs. 200 crores and hence, they could not be considered as good comparable companies. Held: Companies having turnover more than Rs. 200 crores upto Rs. 500 crores had to be regarded as one category and those companies could not be regarded as comparables with assessee-company having turnover of less than Rs. 200 crores.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 92C
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