TaxTMI 
TaxTMI 
2026 (9) TMI 763
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....the assessee is a firm and in the business of rendering information technology software services. The assessee is rendering service to its associated enterprises i.e. Travel Centric Technology Ltd., United Kingdom. The assessee filed its return of income on 21/11/2022. The case was selected for scrutiny under CASS to examine the large value of international transactions in services in comparison to the revenue earned from the sale of services for ITeS and large value of international transactions in services in comparison to the revenue earned from the sale of services shown in ITR. The notice u/s. 143(2) was issued and a reference was made to the TPO. Subsequently, the Ld.TPO, after rejecting the transfer pricing study made by the assessee....
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...., UK since the four companies are having very huge turnovers when compared with the assessee. The Ld.AR submitted that even though the assessee had disputed the inclusion of 8 companies as comparables by the Ld.TPO, now they are restricting the same to 4 companies, such as Tata Consultancy Services, LTIMindtree Ltd., Mindtree Ltd. and Tata Elxsi Ltd. Similarly, the Ld.AR had not pressed ground nos. 11 to 22 in which the assessee had disputed the exclusion of several companies. The Ld.AR finally submitted that the four companies mentioned above included by the Ld.TPO as comparables for arriving the Arms Length Price are excluded and the Arms Length Price has been computed, the assessee will be satisfied. The Ld.AR submitted that even though ....
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....es and found that the companies are having the following turnover. S. No. Name of the company Turnover Rs. (In crores) 1. Tata Consultancy Services 1,60,341 2. LTI Mindtree Ltd. 14,406 3. Mindtree Ltd. 10,525 4. Tata Elxsi Ltd. 2,471 9. The assessee had a turnover of Rs. 33 crores. The assessee in their written submissions, relied on the several factors for the exclusion of these companies, but we are satisfied that on the basis of the turnover filter alone, the above said four companies could not be taken as comparable companies. The orders relied on by the assessee are as follows: a) Wipro GE Healthcare Ltd. vs. DCIT (2026) 186 taxmann.com 324 (Bangalore) b) Oplus India Res....