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        Case ID :
        Income Tax

        ITAT excluded four entities (Eclerx Services Ltd., TCS E-serve...

        Transfer Pricing: Four Companies Excluded from Comparable Array Due to Acquisitions and Rule 10B(4) Compliance Issues

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                          Cases where this provision is explicitly mentioned in the judgment/order text; may not be exhaustive. To view the complete list of cases mentioning this section, Click here.
                            Provisions expressly mentioned in the judgment/order text.
                                ITAT excluded four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech. Mahindra Ltd.) from the comparable array in transfer pricing adjustment. Two entities (Infosys BPO and Tech Mahindra) underwent extraordinary acquisitions within the prescribed two-year period under Rule 10B(4) and failed to meet the related party transaction filter of less than 25%. The tribunal rejected Revenue's argument regarding turnover filter, citing Bombay HC precedent in Pentair Water India Pvt. Ltd. case which had previously upheld exclusion based on turnover filter. ITAT directed TPO to recompute transfer pricing adjustment excluding all four entities, noting that assessee's IT-enabled services segment remained unchanged across assessment years 2010-11 to 2013-14.
                                Note: It is a system-generated summary and is for quick reference only.
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