https://www.taxtmi.com/caselaws?id=259475 The ITAT Delhi held that Infosys Technologies Ltd., Persistent Systems Ltd., and Wipro Ltd. are not comparable to the assessee for transfer pricing purposes due to differences in business models, risk profiles, and service offerings. Infosys and Persistent Systems were excluded following precedents and factual dissimilarities, while Wipro was excluded due to its scale, R&D expenditure, and diversified operations. Similarly, Choksi Laboratories Ltd. and WAPCOS Ltd. were excluded as comparables for marketing support services due to differing service nature and lack of segmental data. The CIT(A)'s allowance of recruitment and training expenses as revenue expenditure was upheld. However, the addition related to sundry balances written off was set aside and remanded to the AO for fresh consideration with an opportunity to the assessee, as CIT(A) had relied on evidence not before the AO. The decision favored the revenue on the latter issue for statistical purposes. en-us Thu, 23 Apr 2015 00:00:00 +0530 Fri, 25 Jul 2025 17:57:00 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=259475 The ITAT Delhi held that Infosys Technologies Ltd., Persistent Systems Ltd., and Wipro Ltd. are not comparable to the assessee for transfer pricing purposes due to differences in business models, risk profiles, and service offerings. Infosys and Persistent Systems were excluded following precedents and factual dissimilarities, while Wipro was excluded due to its scale, R&D expenditure, and diversified operations. Similarly, Choksi Laboratories Ltd. and WAPCOS Ltd. were excluded as comparables for marketing support services due to differing service nature and lack of segmental data. The CIT(A)'s allowance of recruitment and training expenses as revenue expenditure was upheld. However, the addition related to sundry balances written off was set aside and remanded to the AO for fresh consideration with an opportunity to the assessee, as CIT(A) had relied on evidence not before the AO. The decision favored the revenue on the latter issue for statistical purposes. Case-Laws Income Tax Thu, 23 Apr 2015 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=259475