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Documents citing Sun Life India Service Centre Pvt. Ltd., ... vs Acit, Gurgaon on 19 March, 2018

Adp Private Limited (31/10/2015), ... vs Dcit, Circle-1( 1), Hyderabad on 3 February, 2022

"11. We find that the Tribunal noted that the TPO had selected KALS Information System Ltd. and Thirdware Solution Ltd. as being comparable, whereas the case of assessee was that both the said ITA No 2233 of 2018 ADP Private Ltd Hyderabad concerns were functionally different. With regard to KALS Information System Ltd., it was pointed out that the said company was earning income from sale of application software and segmental information with respect to software services were available. In respect of Thirdware Solution Ltd., it was pointed out that the said concern was engaged in software development, trading of software licences and training implementation activities apart from software development. Another contention was raised that Thirdware Solution Ltd. was super profit earning company and was also engaged in the business of software licences and trading of implementation activities. The Tribunal taking note of the Special Bench decision in the case of Maersk Global Centres (India) Pvt. Ltd. Vs. ACIT vide ITA No.7466/M/2012 in respect of super profits and inclusion of concern Thirdware Solution Ltd., held that the said concern was not comparable and observed as under:-
Income Tax Appellate Tribunal - Hyderabad Cites 27 - Cited by 9 - Full Document

Adp Private Limited , Hyderabad vs Dy. Commissioner Of Income Tax , ... on 18 December, 2020

"11. We find that the Tribunal noted that the TPO had selected KALS Information System Ltd. and Thirdware Solution Ltd. as being comparable, whereas the case of assessee was that both the said Page 24 of 44 ITA No 2233 of 2018 ADP Private Ltd Hyderabad concerns were functionally different. With regard to KALS Information System Ltd., it was pointed out that the said company was earning income from sale of application software and segmental information with respect to software services were available. In respect of Thirdware Solution Ltd., it was pointed out that the said concern was engaged in software development, trading of software licences and training implementation activities apart from software development. Another contention was raised that Thirdware Solution Ltd. was super profit earning company and was also engaged in the business of software licences and trading of implementation activities. The Tribunal taking note of the Special Bench decision in the case of Maersk Global Centres (India) Pvt. Ltd. Vs. ACIT vide ITA No.7466/M/2012 in respect of super profits and inclusion of concern Thirdware Solution Ltd., held that the said concern was not comparable and observed as under:-
Income Tax Appellate Tribunal - Hyderabad Cites 25 - Cited by 1 - Full Document

Aditya Birla Sun Life Amc ... vs The Deputy Commissioner Of Income Tax ... on 6 February, 2026

34. Respectfully following the ratio laid down by the co-ordinate Bench in Aditya Birla Sun Life AMC Private Limited v. ACIT (supra), and applying the principles enunciated in paras 18 to 25 thereof to the facts of the present case, we hold that the assessee is entitled to deduction under section 80G of the Act in respect of the impugned amount of Rs. 92,31,072/-.
Income Tax Appellate Tribunal - Mumbai Cites 32 - Cited by 0 - Full Document

Pr Commissioner Of vs M/S Zyme Solutions P Ltd on 26 June, 2018

In taking this view we are fortified by the Special Bench decision in the case of Maersk Global Centres (India) P. Ltd v. ACIT [ITA.7466/Mum/2012, dt.07-03-2012]. Further analysis of voluminous data and deciphing meaningful information there from which helps build core business strategy is a highly skilled function, requires advanced programming skills and knowledge of data mining. Data analytics is no ordinary job like daily business accounting or book-keeping. It is in no way comparable to a low end-business outsource function. Accordingly, we are of the opinion that Acropetal Technologies Ltd (seg), cannot be excluded from the list of comparables. Ordered accordingly.
Karnataka High Court Cites 10 - Cited by 0 - Full Document

Ts Tech Sun India Private Limited ,New ... vs The Assistant Commissioner Of Income ... on 28 January, 2026

(2) The Principal Commissioner or the Commissioner shall, on receipt of a communication from the collegium under sub- section (1), notwithstanding anything contained in sub-section (3) of section 253 or clause (a) of sub-section (2) of section 260A, 5 ITA No. 4391/Del/2024 T S Tech Sun India Pvt. Ltd. Vs. ACIT direct the Assessing Officer to make an application to the Appellate Tribunal or the jurisdictional High Court, as the case may be, in such form as may be prescribed within a period of one hundred and twenty days from the date of receipt of the order of 29[the Joint Commissioner (Appeals) or] the Commissioner (Appeals) or of the Appellate Tribunal, as the case may be, stating that an appeal on the question of law arising in the relevant case may be filed when the decision on such question of law becomes final in the other case.
Income Tax Appellate Tribunal - Delhi Cites 45 - Cited by 0 - Full Document

Ito, New Delhi vs M/S. Netlink Software (P) Ltd., New ... on 11 December, 2019

22. So far as Think Soft Global Services is concerned, we find this company was rejected by the TPO mentioning low end functions as compared to the assessee. The submissions of the assessee that this company is broadly similar to the assessee and TNMM rejection brought functional inability and the company meets all filters applied by the assessee as well as the TPO were rejected by the TPO. We find the DRP held that the company is into software validation and 14 ITA Nos.6765 & 6782/Del/2015 verification services which are different from software development services and hence not comparable. It is the submission of the ld. counsel that TNMM is tolerant to some functional differences as it requires only broad function and product/service comparability in comparison to other traditional transactional method. Referring to the decision of the Mumbai Special Bench of the Tribunal in the case of Maersk Global Centres (India) (P) Ltd. vs. ACIT, 147 ITD 83, the ld. counsel drew the attention of the Bench to para 62 of the order which reads as under:-
Income Tax Appellate Tribunal - Delhi Cites 27 - Cited by 0 - Full Document
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