https://www.taxtmi.com/caselaws?id=766638 ITAT Delhi ruled in favor of the assessee regarding TP adjustment and comparable selection. The tribunal directed exclusion of four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech Mahindra Ltd.) from the comparable set. Two entities (Infosys BPO Ltd. and Tech Mahindra Ltd.) were excluded due to extraordinary acquisition events within the prescribed two-year period under Rule 10B(4) and failure to satisfy the related party transaction filter of less than 25%. The Revenue's arguments were rejected, with the tribunal citing Bombay HC precedent supporting exclusion based on turnover filter. TPO was directed to recompute adjustments accordingly. en-us Wed, 29 Jan 2025 00:00:00 +0530 Sat, 01 Mar 2025 08:25:45 +0530 TaxTMI RSS Generator https://www.taxtmi.com/caselaws?id=766638 ITAT Delhi ruled in favor of the assessee regarding TP adjustment and comparable selection. The tribunal directed exclusion of four entities (Eclerx Services Ltd., TCS E-serve Ltd., Infosys BPO Ltd., and Tech Mahindra Ltd.) from the comparable set. Two entities (Infosys BPO Ltd. and Tech Mahindra Ltd.) were excluded due to extraordinary acquisition events within the prescribed two-year period under Rule 10B(4) and failure to satisfy the related party transaction filter of less than 25%. The Revenue's arguments were rejected, with the tribunal citing Bombay HC precedent supporting exclusion based on turnover filter. TPO was directed to recompute adjustments accordingly. Case-Laws Income Tax Wed, 29 Jan 2025 00:00:00 +0530 https://www.taxtmi.com/caselaws?id=766638