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| The Tax Publishers2021 TaxPub(DT) 0853 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys BPO Ltd., and TCS e-Serve Ltd. had turnover of Rs. 1,312 crores and Rs. 1,578 crores respectively, whereas assessee's turnover was only Rs. 94 crores (less than Rs. 100 crores and less than 1/10th of turnover of said two companies. Accordingly, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Turnover filter
Assessee rendered IT enabled services to its AE abroad. TPO considered Infosys BPO Ltd. and TCS E-Serve Ltd. as comparables to assessee's case. Held: Infosys BPO Ltd., and TCS e-Serve Ltd. had turnover of Rs. 1,312 crores and Rs. 1,578 crores respectively, whereas assessee's turnover was only Rs. 94 crores (less than Rs. 100 crores and less than 1/10th of turnover of said two companies. Accordingly, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
INCOME TAX ACT, 1961
Section 92C
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