Search Results Page

Search Results

1 - 7 of 7 (0.29 seconds)
M/S Cengage Learning India Pvt. Ltd., ... vs Ito, New Delhi on 11 May, 2018 cites

Turbo Energy Limited, Chennai vs Dcit, Chennai on 3 May, 2017

Further, the claim of the 37 assessee that it is a persistent loss making company also cannot be considered because during the year the company has earned profit of Rs. 20740984/- against a loss in the previous year of Rs. 4488926/-. It is further submitted that for AY 2004-05 and FY 2005-06 the assessee has incurred loss of 59.07% and 44.21% and in current year the profit is 34.30%. Therefore, this company has fluctuating profits. On the identical reasons the coordinate bench in Cummins Turbo Technologies Ltd Vs. DCIT (supra) considering the decision of the special bench in case of Maersk Global Centers India Pvt. Ltd Vs. ACIT (supra) has excluded this comparable holding as under:-
Income Tax Appellate Tribunal - Chennai Cites 55 - Cited by 10 - Full Document

Stryker Global Technology Center Pvt. ... vs Acit, New Delhi on 24 January, 2017

Further, the claim of the 37 assessee that it is a persistent loss making company also cannot be considered because during the year the company has earned profit of Rs. 20740984/- against a loss in the previous year of Rs. 4488926/-. It is further submitted that for AY 2004-05 and FY 2005-06 the assessee has incurred loss of 59.07% and 44.21% and in current year the profit is 34.30%. Therefore, this company has fluctuating profits. On the identical reasons the coordinate bench in Cummins Turbo Technologies Ltd Vs. DCIT (supra) considering the decision of the special bench in case of Maersk Global Centers India Pvt. Ltd Vs. ACIT (supra) has excluded this comparable holding as under:-
Income Tax Appellate Tribunal - Delhi Cites 6 - Cited by 11 - Full Document

M/S.Sundaram Fin.Ltd vs Asst.Commissioner Of Income ... on 11 September, 2012

"8. We have carefully considered the rival stands on this aspect. In the context of the controversy relating to the exclusion of abnormal profit making concerns, a reference has been made to the decision of the Special Bench of the Tribunal in the case of Maersk Global Centres (India) (P.) Ltd. v. Asstt. CIT [2014] 147 ITD 83/43 taxmann.com 100 (Mum. - Trib.). The relevant observations of the Bench are as under :--
Supreme Court of India Cites 3 - Cited by 237 - Full Document

Principal Commissioner Of Income Tax 01 vs Actis Global Service Pvt. Ltd on 13 April, 2018

60. We have carefully considered the rival contentions and perused the annual account of the above company at page No. 179 to 281 of the paper book. According to that, this company is engaged in CRM, Finance and Accounting, knowledge services, order management and procurement and human resources for various vertical business undertaking. Further, the ld DRP at page No. 8 of its direction has noted that all the information 44 were provided by the TPO to the assessee obtained u/s 133(6) of the Act and therefore, there is no objection about the functional dissimilarity with the company. Further, it was submitted by the ld AR that this company has operating revenue of Rs. 649 crores whereas the assessee gross revenue is only Rs. 55.94 lakhs, therefore, by mere size this company is required to be excluded. Hon'ble Delhi High Court in case of Pr CIT Vs. Actis Global Services finds merit that size and scale of the operations makes it inapposite comparable. In the present case the difference in the gross revenue from Rs. 649 crores of the comparable itself which is more than 1200 times of the turnover the assessee company. In view of this we direct the exclusion of the Infosys BPO ltd from the comparability analysis.
Supreme Court - Daily Orders Cites 0 - Cited by 8 - Full Document
1