Thursday, 4 September 2014

TP adjustments on basis of comparables with higher related party transactions aren’t justified

IT/ILT : Where TPO made certain addition to assessee's ALP in relation to international transactions entered into with AE relating to software development services, in view of fact that in case of one comparable selected by TPO, there was merger of another company which resulted in its earning high operating margin and, moreover, some other comparables were found inappropriate on account of functional difference and related party transactions, impugned addition was to be set aside and, matter wa


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