| |
| The Tax Publishers2021 TaxPub(DT) 0910 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Assessee's turnover was Rs. 47,46,66,638. It would, therefore, fall within the category of companies in the range of turnover between Rs. I crore and Rs. 200 crores and, therefore, companies having turnover of more than Rs. 200 crores were to be eliminated from the list of comparables.
|
Transfer pricing - Determination of ALP - Selection of comparables - TPO not applied upper turnover limit
Assessee rendered software development services to its AE abraod. TPO while selecting comparables applied a lower turnover filter of Rs. 1 crore, but had not chosen to apply any upper turnover limit. Held: Assessee's turnover was Rs. 47,46,66,638. It would, therefore, fall within the category of companies in the range of turnover between Rs. I crore and Rs. 200 crores and, therefore, companies having turnover of more than Rs. 200 crores were to be eliminated from the list of comparables.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2009-10
INCOME TAX ACT, 1961
Section 92C
 SUBSCRIBE FOR FULL CONTENT
|