Tuesday 22 July 2014

TP adjustment set aside as average margin of selected comparables was lower than operating margin of

IT/ILT: Where TPO made addition to assessee's ALP in respect of ITES services provided to its AE, in view of fact that classification of ITES into low-end BPO services and high-end KPO services for comparability analysis was not just and proper and, moreover, mean margin of eleven companies comprising six selected by assessee and five by TPO was lower than assessee's operating profit margin, impugned addition was to be set aside


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