COMPARABLES FOR ITES FOR AY 2008-09

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 taxmann.com 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 […]

ACUMEN FUND ADVISORY SERVICES INDIA (P.) LTD VS DCIT [2014] 50 TAXMANN.COM 317 (MUMBAI- TRIB.)

The issue for consideration was whether Motilal Oswal Investment Advisor, engaged in merchant banking activity can be compared with Assessee engaged in investment advisory services. Facts: For AY 2009-10, the assessee rendered investment advisory services to its AE. The assessee applied TNMM as the MAM and arrived at mean margin of 18.60% (PLI=OP/OR) by selecting […]

COST OF TERMINATION OF PROPERTY PURCHASE AGREEMENT – WHETHER OPERATING OR NON-OPERATING FOR PLI COMPUTATION

Rule 10B of Income Tax Rules provides methodology for computation of ALP.  Under TNMM, ‘net profit’ is used as benchmark for ALP computation.  Rule 10B(1)(e)(i) provides for considering “net profit margin realised by the enterprise from an international transaction or SDT entered into with an associated enterprise”.  Rule 10B(1)(e)(ii) provides for computation of ‘net profit […]

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