Changing the Most Appropriate Method by the Assessee from one selected in TP Study

Section 92C(1) provides that ALP of international transaction and SDT shall be determined by adopting “MAM”, having regard to the nature of transaction or class of transaction or class of associated persons or functions performed by such persons or such other relevant factors as the Board may prescribed. Rule 10C lays down the guiding principles […]


LIONBRIDGE TECHNOLOGIES PVT LTD VS ITO [2014] 48 TAXMANN.COM 46 (MUMBAI – TRIB.) – The Tribunal held that comparables providing KPO services like engineering or data analysis/processing etc cannot be comparable with the assessee engaged in providing low end back-office operations. The assessee was engaged in providing low end back-office support services. During AY 2007-08, […]

BRIGAE CORPORATION INDIA (P.) LTD vs ACIT [2014] 48 176 (Chennai- Trib.)

Facts: For AY 2007-08, the Assessee was engaged in the business of providing customer supporting services in the form of email support, voice support & chatting and financial information support for customers identified by the AEs. The TPO selected M/s.Eclerx Services Ltd as a comparable. The CIT(A) observed that Eclerx has an operating profit of […]

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