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Vodafone India Services Private Ltd.,, ... vs The Deputy Commissioner Of Income Tax, ... on 23 January, 2018

xxxxxxxxxx 17.3 We have heard the rival submissions and perused and carefully considered the material on record. It is seen from the details on record that this company i.e. Persistent Systems Ltd., is engaged in product development and product design services while the assessee is a software development services provider. We find Date of Judgment 08-08-2018 I.T.A.No.374/2017 The Pr. Commissioner of Income-tax & Anr. Vs. M/s. Analog Devices India Pvt. Ltd., 7/10 that, as submitted by the assessee, the segmental details are not given separately. Therefore, following the principle enunciated in the decision of the Mumbai Tribunal in the case of Telecordia Technologies India Pvt. Ltd. (supra) that in the absence of segmental details/information a company cannot be taken into account for comparability analysis, we hold that this company i.e. Persistent Systems Ltd. ought to be omitted from the set of comparables for the year under consideration. It is ordered accordingly.
Income Tax Appellate Tribunal - Ahmedabad Cites 104 - Cited by 22 - Full Document
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