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Tirath Ram Ahuja P. Ltd. vs Commissioner Of Income-Tax on 31 August, 1990

"10.2 Having gone through the orders of the authorities below, we find that on the applicability/rejection of the above named 13 comparables the objections raised before us as summarized hereinabove in the tabular format supported with cited decisions thereunder requires fresh consideration of the ld. TPO for just and fair assessment. As in the case of Ramp Green Solutions (P) Ltd. Vs. CIT (supra) it has been held that Vishal Information Technologies Ltd. and E-clerx Services Pvt. Ltd. cannot be taken as comparables for determining the ALP as both are in KPO Services.
Supreme Court of India Cites 1 - Cited by 21 - K J Shetty - Full Document

M/S. Venus Township India (P) Ltd, ... vs The Dcit. Central Circle-1(1), ... on 12 November, 2020

The authenticity of the order can be re-verified from Delhi High Court Order Portal by scanning the QR code shown above. The Order is downloaded from the DHC Server on 08/07/2024 at 20:40:49 by Infosis vis-a-vis the assessee, hence, it is not comparable. Similar observations are applicable in the case of present assessee as well. Again in the case of ICC India P. Ltd. Vs. DCIT (supra) observations on the comparability of Wipro, Infosis BP Ltd., HCL Comnet Systems & Services Ltd., Accentia, Maplc Solutions, Triton Corporation Ltd. have been made.
Income Tax Appellate Tribunal - Ahmedabad Cites 81 - Cited by 43 - Full Document

Information System Resource Centre ... vs Dcit 2(2), Mumbai on 22 May, 2018

Again in the case of Capital IQ Information Systems (P) Ltd., vs. DCIT (supra) observations on the applicability of the comparables Triton Corporation Ltd., has been made. There are other decisions also cited above by the ld. AR, wherein observations on the applicability of different comparables have been made and since those comparable have also been applied in the case of the present assessee, those observations are required to be examined with the facts of the case of the present assessee to arrive at a just and fair conclusion. We, while setting aside the orders of the authorities below, on the issues raised in ground Nos. 7 to 11 remand the matter to the file of the ld. TPO to decide the applicability of the disputed comparables, after affording opportunity of being heard to the assessee while taking into consideration the decisions cited above as well as the objections raised by the assessee. The ground Nos. 7 to 11 are accordingly allowed, for statistical purposes."
Income Tax Appellate Tribunal - Mumbai Cites 0 - Cited by 0 - Full Document

Microsoft Global Services Centre ... vs Acit., Circle-16(2), Hyderabad, ... on 17 April, 2023

In the case of Maersk Global Centre India Pvt. Ltd. Vs. ACIT (supra) the Special Bench of the Tribunal has noted that E- clerx is engaged in data analysis, date processing services, pricing analysis, building optimization, contend operation, sales and marketing support, product data management, Revenue management and in addition, E-clerix also offered financial services such as real time Capital Market, Middle and back office support, portfolio risk management services and various critical data management services and various critical data services. Clearly, the aforesaid services are not comparables with the services rendered by the assessee. Further, the functions undertaken are also not comparable with the assessee.
Income Tax Appellate Tribunal - Hyderabad Cites 1 - Cited by 0 - Full Document
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