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Acit, Cirlce-5 (1), , Hyderabad vs Market Tools Research Private Limited , ... on 22 July, 2024
cites
Section 92C in The Income Tax Act, 1961 [Entire Act]
Acit, Gurgaon vs M/S. Motorola India Pvt. Ltd., Gurgaon on 24 August, 2018
9.8 We have gone through the record and considered the rival
contentions of the parties. From the perusal of the financial
statement and the functions performed by TCS e-Serve
International Limited, we are not in agreement with the submissions
of the assessee that this company is financially different from that of
the assessee. In fact, the activities of the assessee company are
broadly matching with the company namely, TCS e-Serve
International Limited. Further, the case law i.e., ACIT Vs. Hundai
Motors India Engineering Pvt. Ltd (supra) relied upon by the
assessee is not in favour of the assessee as in the said order it was
mentioned that exceptional circumstances were happened during
19
the year under consideration. The perusal of page 217 of the paper
book mentions about the Directors Report wherein, it is mentioned
that the financial year of 2009-10 is the second year of operation of
the company as the step down subsidy of TCS and it has earned
total income of Rs.150.40 crores which is more than three times
higher than that of the previous year. At page 219, it is mentioned
that this company is into the broad range of services, catering to the
process management, requirement of vide range of financial
products, and enterprise support system. Further, at page 225,
against the background and principle activities, it is mentioned that
the company is into ITeS /BPO services primarily to City group
entities globally. Thus, it is clear that the documents referred by the
assessee no where shows any extra ordinary events happened
during the year and on the contrary, it shows that the assessee
company is offering services to City Group to its corporate and its
retail clients. Thus, the objection of the assessee that is without any
basis. In the light of the above, the objection of the assessee for
exclusion of this company is rejected.
The Income Tax Act, 1961
Section 271AA in The Income Tax Act, 1961 [Entire Act]
Section 271BA in The Income Tax Act, 1961 [Entire Act]
Section 92CA in The Income Tax Act, 1961 [Entire Act]
Section 12 in The Income Tax Act, 1961 [Entire Act]
Assistant Commissioner Of Income Tax vs Tata Elxsi Ltd. on 22 February, 2019
"11.3 We have heard the submissions of the parties and perused the
material on record with regard to the aforesaid company. As can be
seen from the website extract of the aforesaid company, it is engaged
in providing services which are in the nature of KPO. Further, on
perusal of the annual report of the company, furnished in the paper-
book, it is seen that the said company is engaged in providing Niche
services, as well as developed its own brand 'Exdion' to target the
insurance industry in US. The Annual Report further reveals that the
company has been running marketing campaigns in the US for
expanding its plant base in relation to the brand developed by it. The
assessee however, is only providing IT Enabled Services to its AE and
does not have the diversified activities like the aforesaid company.
The Bangalore Bench of the Tribunal in the case of Symphony
Marketing Solutions India P. Ltd. V/s. ITO (supra), while considering
the issue of aforesaid company as a comparable accepted the
assessee's contention that Crossdomain cannot be compared to a
routine ITES provider and directed for exclusion of the same from the
list of comparables.