Research support services transfer pricing comparables and employees' PF timing glitches: low-turnover company excluded; PF disallowance deleted.

X X   X X   Extracts   X X   X X

Full Text of the Document

X X   X X   Extracts   X X   X X

....For benchmarking research support services, a company selected as a comparable was held to fail the turnover filter since its turnover was only INR 3.65 crores; the AO/TPO was directed to rework the arm's length analysis by applying filters correctly and excluding that company, with consequent TP adjustment, if any, to be recomputed. On disallowance of employees' PF contribution for delayed credit, where the assessee had remitted the amount and it was debited from its bank within the stipulated date but credit to EPFO was delayed due to technical glitches beyond its control, the disallowance was deleted and the ratio in Checkmate Services was held inapplicable, resulting in the appeal being allowed. - ITAT....