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| The Tax Publishers2021 TaxPub(DT) 1128 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Larsen and Toubro Infotech Ltd., and Mindtree Ltd., Sasken Communications Technologies Ltd. having high turnover of more than Rs. 200 Crores deserved to be excluded from set of comparables by applying an upper turnover limit.
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Transfer pricing - Determination of ALP - Selection of comparables - Higher turnover
Assessee rendered software development services to its AE abroad. TPO considered L&T Infotch Ltd., Mindtree Ltd. and Sasken Communication Technologies Ltd. as comparable to assessee's case. Held: Larsen and Toubro Infotech Ltd., Mindtree Ltd., and Sasken Communications Technologies Ltd. having high turnover of more than Rs. 200 Crores deserved to be excluded from set of comparables by applying an upper turnover limit.
Followed:Genesis Integrating Systems v. Dy. CIT (2012) 20 Taxmann.com 715 (Bang-Trib) : 2012 TaxPub(DT) 2253 (Bang-Trib) and Autodesk India Pvt. Ltd. v. Dy. CIT (2018) 96 Ttaxmann.com 263 (Bang-Trib) : 2019 TaxPub(DT) 1523 (Bang-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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