Transfer pricing comparables selection and working capital adjustment u/r 10B(1)(e)(iii), remanded for recomputation with rejected comparables include...
Company oppression/mismanagement petition amendments and maintainability after alleged share transfer and forgery claims; tribunal order quashed for l...
ITAT partly allowed revenue's and assessee's appeals in a TP dispute concerning software development and EDS segments. Inclusion of CADSYS (India) Pvt. Ltd. was permitted; however, even with this comparable, assessee's margin remained within arm's length, rendering EDS-related grounds academic and dismissed. For the software development segment, ITAT directed exclusion of Infosys Ltd. on turnover filter, upheld exclusion of Three Sixty Logica Testing Services Pvt. Ltd., Indianic Infotech Ltd., Nihilent Ltd., and Cybage Software Pvt. Ltd. from comparables, and remanded the issue of Evoke Technologies Ltd. to AO/TPO for reconsideration. AO/TPO was directed to recompute ALP in accordance with these findings.
ITAT partly allowed revenue's and assessee's appeals in a TP dispute concerning software development and EDS segments. Inclusion of CADSYS (India) Pvt. Ltd. was permitted; however, even with this comparable, assessee's margin remained within arm's length, rendering EDS-related grounds academic and dismissed. For the software development segment, ITAT directed exclusion of Infosys Ltd. on turnover filter, upheld exclusion of Three Sixty Logica Testing Services Pvt. Ltd., Indianic Infotech Ltd., Nihilent Ltd., and Cybage Software Pvt. Ltd. from comparables, and remanded the issue of Evoke Technologies Ltd. to AO/TPO for reconsideration. AO/TPO was directed to recompute ALP in accordance with these findings.
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