taking the straight line (crow's flight) distance by using
Global Positioning System measured the distance to be 7.5 k.m and
held that
Dcit, vs M/S Sap Labs India Pvt. Ltd.,, Bangalore on 6 April, 2018
IN
requesting for inclusion of only one
company i.e. R Systems International Ltd. and as per ground no.
IT(TP)A No. 457/Bang/2016 ... companies
i.e. Infosys BPO Ltd., Accentia Technologies Ltd., Cosmic Global
Ltd. and Eclerx Services Ltd. Regarding ground nos. 3 to 7, he
submitted that
list of comparables in
order to determine the ALP:
1. Lanco Global Systems Ltd.,
2. Sasken Communication Technologies Ltd.,
3. R S Software (India ... taken following 17 comparables:
1. Bodhtree Consulting Limited
2. Lanco Global Systems Ltd.,
3. Exensys Software Solutions Limited
4. Sankhya Infotech Limited
5. Sasken Networks
Exports Ltd, is rejected
ii) Larsen & Toubro Ltd & Persistent Systems Ltd, are
remitted back to the file of TPO to decide afresh ... Software
Technologies Ltd is rejected;
iv) The ground for inclusion of Thinksoft Global Services
Ltd is rejected
v) The four comparables namely, Acropetal Technologies
erred in law and on facts by including Kals
Information Systems Ltd. on the grounds of functional similarity,
whereas this comparable should be excluded ... Global
Services Limited and FCS Software Solutions Limited, which were
excluded by the Ld. AO/ Ld. TPO on the basis of high working capital
position
M/S. Ntt Data Global Services Private ... vs The Joint Commissioner Of Income Tax, ... on
uphold
exclusion of Tata Elxsi Ltd., Sasken Communication Technologies
Ldt, Persistent Systems Ltd., L&T Infotech Ltd., and Infosys Ltd.,
by applying turnover filter ... under SWD Segment and for ITeS
Segment, Infosys BPO Ltd., iGate Global Ltd., and Mindtree Ltd.,
by applying turnover filter, from final list.
We therefore
issue
IT(TP)A No.279/Bang/2022
M/s. QuEST Global Engineering Services Pvt. Ltd., Belagavi
Page 26 of 38
and hence the view ... rival submissions.
ITAT Bangalore Bench in the case of Genesis Integrating Systems (India)
Pvt. Ltd. v. DCIT, ITA No.1231/Bang/2010, relying
ITAT Bangalore in the case of M/s.
Genesis Integrating System (India) Pvt. Ltd Vs. DCIT in ITA
No/231/(Bang)/2010 ... 7894/Mum/2010.
From the facts as well as legal position discussed above, the
TPO's action would be according to the statutory provision