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Giesecke & Devrient India Pvt. Ltd., ... vs Dcit, New Delhi on 23 August, 2018

He also drew our attention to the fact that there was a merger during the relevant year. Hence, it was submitted that the said comparable deserves to be excluded. It was fairly accepted that though there is no finding of the Ld. DRP on this comparable but since all the material facts were available on record and as there was no dispute on application of filters,the issue could be adjudicated. He relied on the 28 ITA NO. 5924/Del/2012 (Giesecke & Devrient India Pvt. Ltd.) co-ordinate bench's decision in the case of Nokia Siemens Networks India Pvt. Ltd vs. ACIT in ITA No. 333/Del/2013 in which the co- ordinate bench, whilst appreciating the fact that Igate was providing various services and owing to the fact that there was no segmental data, directed its exclusion.
Income Tax Appellate Tribunal - Delhi Cites 41 - Cited by 2 - Full Document

M/S. Motorola Solutions India Pvt. ... vs Dcit, Gurgaon on 31 October, 2019

15.25 LGS Global Ltd.:- This comparable company has abnormal increase in revenue from the previous year i.e. 200%. The Ld. AR submitted that TPO has used diminishing filter to reject companies with diminishing return and on other side selected this company as comparable with such a huge increase in revenue. The Company is engaged in multifarious activities including an end to end service provider and offers variety of services. It is involved in product evaluation, design & development etc. of the products. Further, it also renders BPO services in the field of Human Resources, Life Sciences, Legal Services, Supply Chain Management, Sales and Customer Support etc. Further, the financial statements lacks in providing the segmental results as well. The Ld. AR relied upon the decision in case of M/s Nokia Siemens Networks India vs. ACIT (ITA No. 333/Del/2013 for A.Y. 2008-09), Navisite India Pvt. Ltd. (ITA No. 5329/Del/2012) and Sapient Corpn. (P.)
Income Tax Appellate Tribunal - Delhi Cites 53 - Cited by 2 - Full Document

M/S. Nokia Siemens Networks Pvt. Ltd., ... vs Acit, New Delhi on 1 October, 2018

Since there is case to allow working capital adjustment in assessee's case as held in case of M/s Nokia Siemens Networks India (supra). The issue is identical and hence we direct the TPO to grant working capital adjustment to account for difference in working capital employed by the assessee and the comparable companies. Ground No. 5.8 is partly allowed for statistical purpose.
Income Tax Appellate Tribunal - Delhi Cites 22 - Cited by 0 - Full Document
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