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Mercedes-Benz Research And ... vs Assistant Commissioner Of Income-Tax, ... on 28 November, 2025
cites
The Income Tax Act, 1961
Section 92CA in The Income Tax Act, 1961 [Entire Act]
Tavant Technologies India Private ... vs Dcit, Bangalore on 31 May, 2017
24. The ld. AR. Submitted that the assessee is a captive software
R&D provider and primarily undertakes SAP and non-SAP software
support and maintenance services. The ld. A.R. further submitted
that the company is involved in other services such as enterprise
transformation and change management services, which is
ITA No.972/Bang/2023
& IT(TP)A No.1029/Bang/2023
Mercedes-Benz Research & Development India Pvt. Ltd., Bangalore
Page 23 of 26
evidenced from the annual report. The ld. A.R. also submitted that
as per the website of the company, it provides brand marketing and
transformation services. The ld. A.R. argued that since no
segmental information is available with regard to the various
accounts of services provided by the company, it cannot be
compared with that of the assessee, which is a captive service
provider. The ld. A.R. placed reliance on the decision in the case of
Infinion Technoligies India Ltd. (supra).
Infor (India) Private Limited, ... vs Acit Central Circle-2(1), Hyderabad on 25 August, 2022
19. We heard the parties and perused the materials on record.
We notice that in the case of Infor India Pvt. Ltd. Vs. ACIT (2019)
109 Taxmann.com 435, the Hyderabad Bench of the Tribunal has
considered the similar issue of exclusion based on the foreign
branch income being unaudited and held as follows:
Mcpi Private Limited (Formerly Known As ... vs Acit, Circle 11, Kolkata, Kolkata on 27 May, 2022
29.1 From the perusal of the above findings, we notice that the
company is excluded on the ground of its providing diversified
ITA No.972/Bang/2023
& IT(TP)A No.1029/Bang/2023
Mercedes-Benz Research & Development India Pvt. Ltd., Bangalore
Page 26 of 26
services and the segmental information with regard to the various
business functions is not available. Respectfully following the
above decision of the coordinate bench, we hold that the company
cannot be included in the list of comparables with the assessee's
which is engaged in software development services. Accordingly, we
direct the TPO to exclude the comparable.
Teleca Software Solutions (India) Pvt. ... vs Dcit, Bangalore on 7 January, 2021
& IT(TP)A No.1029/Bang/2023
Mercedes-Benz Research & Development India Pvt. Ltd., Bangalore
Page 19 of 26
15.1 The ratio laid down by the above decision of the coordinate
bench is that the company which is deriving 100% of its income
from writing, modifying, testing of computer program to meet the
specific needs of clients cannot be compared with the company,
which is engaged in the software development services as captive
service provider. Accordingly, we see no reason to interfere with the
decision of ld. CIT(A) in excluding the 360 Logica from the list of
comparables.
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