TaxTMI Login
Just a moment...
Press 'Enter' to add multiple search terms. Rules for Better Search
When case Id is present, search is done only for this
of 
of 
No Folders have been created
Are you sure you want to delete "My most important" ?
NOTE:
of of 
All Case Laws
of of All Case Laws
Note
Bookmark
Share
Don't have an account? Register Here
of <h1>Appeal Dismissed: Functional Dissimilarities Lead to Exclusion of Comparables in ITAT's Decision for AY 2007-08.</h1> <h3>The Pr. Commissioner of Income Tax -4 Versus Honeywell International (India) Pvt. Ltd.</h3> The Pr. Commissioner of Income Tax -4 Versus Honeywell International (India) Pvt. Ltd. - TMI Issues involved: Appeal concerning Assessment Year (AY) 2007-08, challenging exclusion of comparables Accentia Technologies Ltd., Eclerx Services Ltd., Mold-Tek Technologies Limited, and TSR Darashaw Ltd.Summary:Assessment Year 2007-08:The appellant/revenue contested the exclusion of four comparables in the appeal against the order of the Income Tax Appellate Tribunal. The respondent/assessee provided back-office support services and Corporate Service Segment (CSS) to its Associated Enterprises (AEs). The Transfer Pricing Officer (TPO) made upward adjustments in the ITES Segment and CSS. The Commissioner of Income Tax (Appeals) directed the exclusion of comparables, leading to the deletion of the TPO's adjustments. The Tribunal upheld the CIT(A)'s order, emphasizing functional dissimilarities between the companies benchmarked and the respondent/assessee.Comparables Exclusion:The Tribunal found functional dissimilarities between the respondent/assessee and the comparables. Accentia faced an amalgamation, Eclerx and Mold-Tek provided high-end KPO services unlike the respondent, and TSR merged with Tata Share Registry, operating in BPO/KPO with high margins from software development for payroll processing. The Tribunal's factual findings on dissimilarities were detailed in the order.Conclusion:No substantial question of law was proposed by the appellant/revenue challenging the Tribunal's findings. The Court declined to interfere with the impugned order, closing the appeal as no legal issue merited consideration. Parties were directed to act based on the digitally signed copy of the order.
TaxTMI 
TaxTMI 
