TaxTMI 
TaxTMI 
2019 (9) TMI 1747
X X X X Extracts X X X X
X X X X Extracts X X X X
....aised many grounds, the Ld A.R restricted his arguments to the selection of comparable companies relating to the addition made on account of Transfer Pricing adjustment. Accordingly, we have restricted ourselves to the selection of comparable companies. Accordingly, all other grounds are not adjudicated. 3. The facts relating to the above said issue are discussed in brief. The assessee herein is a wholly owned subsidiary of KBACE Technologies Inc., USA. It is engaged in the business of providing Software Development Services to KBACE, USA. During the year under consideration, the assessee has entered following international transactions with its Associated Enterprise (AE) :- Service Income Rs. 1619.69 lakhs Deferred Receivables Rs. 163....
X X X X Extracts X X X X
X X X X Extracts X X X X
.... category of Rs. 1 to 200 crores. He further submitted that the turnover of following comparable companies selected by TPO exceeds Rs.200 crores and accordingly submitted that these companies are required to be excluded on "turnover filter". Name of company Turnover (a) Larsen & Toubro Infotech Ltd 3613.42 crores (b) Mind Tree Limited 1640.80 crores (c) Persistent Systems Ltd 996.50 crores (d) R.S. Software India Ltd 293.22 crores (e) Tech Mahindra Ltd 6001.90 crores 7. The Ld D.R also concurred with the view of Ld A.R that the above said five companies are required to be excluded on the criteria of turnover filter. The Ld A.R submitted that an identical view has been taken by the co-ordinate bench in the case of Mobility Infot....
X X X X Extracts X X X X
X X X X Extracts X X X X
....m afresh in the light of new facts brought before us. Accordingly, we restore both the companies to the file of AO/TPO. 10. With regard to Sankhya Infotech Ltd, the claim put forth before us by the assessee is contradictory to the findings given by TPO. Hence we are of the view that this company also requires examination afresh. Accordingly, we restore this company also to the file of AO/TPO. 11. The Ld A.R prayed that the following three companies may also be taken as comparable companies. (a) Caliber Point Business Solutions Ltd (Seg) (b) CAT Technologies Ltd (c) Evoke Technologies P Ltd He submitted that the assessee had prayed for inclusion of above said three companies before Ld DRP. However, Ld DRP rejected the prayer of the ....