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| The Tax Publishers2021 TaxPub(DT) 0745 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
In transfer pricing, comparability of assessee has to be made with other companies in identical environment. Therefore, same financial period of both assessee and the comparable should be considered for comparison. In view of this, TPO was directed to compute margin of R. Systems International Ltd. after taking into consideration financial results of four quarters, which had been considered in the case of assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Different financial year ending
Assessee rendered IT enabled services to its AE abroad. TPO considered R systems International Ltd. as comparable to assessee's case. Assessee submitted that said company follows year ending, which was different from assessee, accordingly, computation of margin might be remanded to TPO based on quarterly filing of the company. Held: In transfer pricing, comparability of assessee has to be made with other companies in identical environment. Therefore, same financial period of both assessee and the comparable should be considered for comparison. In view of this, TPO was directed to compute margin of R. Systems International Ltd. after taking into consideration financial results of four quarters, which had been considered in the case of assessee.
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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