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Transcend Mt Services Pvt. Ltd., New ... vs Ito, New Delhi on 12 December, 2017 cites

Ceb India Pvt. Ltd., Gurgaon vs Acit, Gurgaon on 17 March, 2017

33. The ld. CIT (A) has granted working capital adjustment to the taxpayer in AY 2005-06 which order has been upheld by the coordinate Bench of the Tribunal by following the decision rendered by Bangalore Bench of the Tribunal in ITA No.1442/BNG/2008 in TNT India Pvt. Ltd. vs. ACIT. So, following the decisions rendered by the coordinate Bench of the Tribunal in taxpayer's own case for AY 2005-06, we are of the considered view that the taxpayer is entitled for working capital adjustment qua margin earned by the comparable companies vis-à- vis the taxpayer.
Income Tax Appellate Tribunal - Delhi Cites 24 - Cited by 43 - Full Document

Continental Construction Ltd vs Commissioner Of Income-Tax, Central-1 on 15 January, 1992

27. Furthermore Nucleus outsources most of its work/services to other vendors / service providers. Coordinate Bench of the Tribunal examined the comparability in Ameriprise India (P) Ltd. and American Express (India)(P.) Ltd. (supra), available at page 52 of the case laws paper book, wherein Nucleus has been ordered to be excluded as a comparable vis-à-vis Ameriprise India (P) Ltd. which is also a captive contract service provider engaged in IT Enabled Back Office service on ground of amalgamation by following M/s. HSBC Electronic Data Processing India Ltd. 17 ITA Nos.4048 & 4501/Del/2013 (supra) and Pr. CIT vs. IHG IT Services (India) Pvt. Ltd. in ITA No.264 of 2016 (Hon'ble Punjab & Haryana High Court).
Supreme Court of India Cites 41 - Cited by 2319 - Full Document

Assistant Commissioner Of Income Tax vs M/S. Business Process Outsourcing ... on 22 August, 2016

31. Coordinate Bench of the Tribunal in ITO vs. Business Process Outsourcing India (P.) Ltd. - (2014) 61 SOT 83 (Bangalore - Trib.) examined the comparability of Tricom vis-a- vis the assessee company ordered to exclude the same on ground of 19 ITA Nos.4048 & 4501/Del/2013 the fact that Tricom develops its own software whereas the assessee has no such software product intangibles. So, keeping in view the RPT of 61.86% and the fact that Tricom develops its own software product and own its own intangibles, it cannot be a suitable comparables vis-à-vis the taxpayer. So, we order to exclude the same. So, in view of the matter, grounds no.1, 1.1.3, 1.1.4, 1.1.6, 1.1.10 and 1.1.11 are determined in favour of the taxpayer GROUNDS NO.1.1.7 & 1.1.8 IN ITA NO.4048/DEL/2013 & ITA NO.4501/DEL/2013
Supreme Court - Daily Orders Cites 0 - Cited by 1 - Full Document
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