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1 - 10 of 57 (2.26 seconds)Section 234B in The Income Tax Act, 1961 [Entire Act]
The Income Tax Act, 1961
Section 92C in The Income Tax Act, 1961 [Entire Act]
Section 37 in The Income Tax Act, 1961 [Entire Act]
Section 92CA in The Income Tax Act, 1961 [Entire Act]
Section 32 in The Income Tax Act, 1961 [Entire Act]
Section 234D in The Income Tax Act, 1961 [Entire Act]
Ensco Maritime Limited As Agent Of Mr. ... vs Dcit, Spl. Range [Alongwith Ita Nos. ... on 26 July, 2004
v) TS R Darshwa Limited
This comparable has been selected by the Ld. Transfer
Pricing Officer which is engaged in 3 segments such as
registrar and transfer agent activity, records management
activity and pay roll and trust fund activity. According to the
Ld. Transfer Pricing Officer and Ld. Dispute Resolution
Panel, this is a good comparable. However, the Ld.
Authorised Representative submitted that this company is
engaged in Share Registry Services and other support
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B G Exploration & Production India Limited V DCIT ITA No 1170/Del/2015
DCIT V B G Exploration & Production India Limited ITA No 1581/Del/2015
AY 2010-11
services. Further as per annual report of the company, it is
primarily engaged in provision of share registry and related
financial services and therefore, cannot be compared with
the Assessee, a captive market support service provider. It
is also contended that company has earned a high profit
margin of 41.86% during the FY 2009-10. The Ld. Authorised
Representative placed reliance in this regard on the decision
of Delhi ITAT in case of Microsoft Corporation India (P.) Ltd
vs. DCIT, ITA 5766/Del/2011. We have carefully considered
the rival contention and perused the balance sheet of the
company, which is placed at page No. 155 - 196 of the
paper book, which says that it is mainly engaged in the
business of registrar and share transfer agent. At page No.
178 of the paper book the segment reporting shows that out
of the total turnover of 20.07 lakhs, Rs. 11.94 Lacs of the
turnover goes to the registry and share transfer agent
business. The functions to be performed with respect to the
registry and share transfer agent are altogether dissimilar to
the functions to be performed by a procurement advisor like
Assessee. It is also not the case of the revenue that only
some of the segment of the comparable is required to be
considered, but the Ld. Transfer Pricing Officer has
considered the whole of the company as functionally
comparable to the Assessee with which we disagree.
Therefore, we direct the Ld. Transfer Pricing Officer/AO to
exclude this comparable for being functionally dissimilar.