TaxTMI 
TaxTMI 
2018 (8) TMI 1202
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....directing to reduce/delete the addition/disallowance of Rs. 1,80,44,570/- on account of arm's length price of international transaction related to provision of I.T. services. 3. At the very outset, the ld. AR pointed out that the grievance raised by the Revenue is neither here nor there as it is not coming out from the ground why the Revenue is aggrieved because the amount mentioned in the ground of appeal is not coming out anywhere from the order of the DRP. 4. Per contra, the ld. DR sought time for revising the ground of appeal. 5. We have given thoughtful consideration to the points raised by the ld. AR. We have carefully perused the order of the DRP. We find force in the contention of the ld. AR. The grievance of the Revenue is neith....
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....38 5 l-gate Global Ltd 24.09 6 Infosys B P O Ltd. 30.17 7 Jindal Intellicom Ltd. 14.95 8 Omega Healthcare 13.11 9 T C S E-Serve International Ltd. 5.43 10 T C S E-Serve Ltd. 65.27 Average 31.81 8. Accordingly, the arm's length of the international transaction related to provision of I.T. enables services was computed as under: Operating Cost(A) 32,03,40,125 Arm's Length Margin (%) 31.81% Margin (B) 10,19,00,194 Arm's Length Price(A+B)=C 42,22,40,319 Price Charged by the assessee(D) 40,02,92,121 Proposed Adjustment 2,19,48,198 9. The TPO further examined the provision of software development services and after considering the comparables used by the assessee vis a vis the comparables use....
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....nbsp;40,02,92,121 42,22,40,319 2,19,48,198 Provision of software development services 33,51,58,550 37,16,60,657 3,65,02,107 Total adjustment u/s 92CA 5,84,50,305 12. Aggrieved by this, the assessee carried the matter before the DRP and strongly supported the comparables used by it. It was brought to the notice of the DRP that the working of the margins computed by the TPO was erroneous and furnished the table containing working of the margins of the comparables as under: S. Company name Adjusted OP/OC 1 Accentia Technologies Limited 40.20 2 Cosmic Global Limited 20.29 3 e4e Healthcare 31.55 4 Fortune Infotech Limited 21.38 5 l-gate Global Limited 24.09 6 Infosys BPO Limited ....
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.... every aspect of the product life- cycle. This company is also into Board designs. From a careful perusal of the profit of this company, we find that this company is equipped to carry out high-end technology driven services and product development which is not the Profile of the assessee. This company has been rightly excluded from the final set of comparables by the DRP. Hence no interference is called for. 17. Coming to Infinite Data Systems Private Limited, this company is wholly owned subsidiary of Infinite Computer Solutions [India] Limited and provides solutions that encompass technical consulting, design and development of software, maintenance systems integration, implementation, testing and infrastructure management services. This....