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Infor India Private Limited (Formerly ... vs Dcit, Circle-2(1), Hyderabad, ... on 26 November, 2019

11. On the other hand, with regard to exclusion of Thirdware Solutions Ltd. the Learned Authorized Representative ("Ld. AR") invited our attention to page No. 263 of the order of the Ld. CIT(A) and submitted that Thirdware Solutions Ltd. has been excluded not only on account of failure of RPT filter but also on the ground of functional dissimilarity. It was submitted that the Ld. CIT(A) has relied upon the decision of the coordinate bench of this Tribunal in the case of Infor (India) Pvt. Ltd. Vs. DCIT in ITA No. 198/Hyd/2021 for A.Y 2016-17, dated 06.10.2021, wherein this company has been held to be functionally not comparable to a routine software development service provider.
Income Tax Appellate Tribunal - Hyderabad Cites 14 - Cited by 9 - Full Document

Hewlett Packard (India) Software ... vs The Deputy Commissioner Of Income Tax, ... on 18 January, 2023

The Ld. AR also relied on Indeed India Operations Private Limited Vs. Dy. CIT in ITA 9 No.254/Hyd/2021 for the A.Y 2016-17, dated 10.08.2022, and ADP Private Limited Vs. Dy. CIT in ITA Nos. 227 & 228/Hyd/2021 for the A.Y 2016-17, dated 03.02.2022, wherein also this company have been held to be functionally not comparable to a routine software development service provider. It was further contended that even independent of the RPT filter, the company fails the test of functional comparability.
Income Tax Appellate Tribunal - Bangalore Cites 28 - Cited by 0 - Full Document
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