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Deputy Commissioner Of Income Tax, ... vs Amd India Private Limited, Bangalore on 17 October, 2025 cites

Autodesk India Private Limited, ... vs Dcit, Bangalore on 8 June, 2018

In the case of Autodesk India P Ltd v DCIT [96 taxmann.com 263], it was held as below "17. The first issue to be decided in Revenue's appeal is the application of turnover filter for exclusion of companies that are otherwise found to be functionally comparable. The Grievance of the revenue in this regard is projected in Gr.No.2 of the Grounds of appeal raised by the revenue in its appeal. The basic facts to be noticed with regard application of turnover filter are that the Assessee's turnover for the relevant previous year was Rs.10.65 crores. The TPO excluded from the list of comparable companies chosen by the Assessee in its TP study companies whose turnover was less than Rs.1 Crore. The contention of the Assessee before the CIT(A) was that while the TPO excluded companies with low turnover, he failed to apply the same yardstick to exclude companies with high turnover compared to the Assessee. The reason for IT(TP)A Nos.1858 & 2031/Bang/2024 AMD India Pvt. Ltd., Bangalore Page 17 of 47 excluding companies with low turnover was that such companies do not reflect the industry trend as their low cost to sales ratio made their results less reliable. The contention of the Assessee was that there would be effect on profitability wherever there is high or low turnover and therefore companies with high turnover should also be excluded from the list of comparable companies.
Income Tax Appellate Tribunal - Bangalore Cites 9 - Cited by 60 - Full Document

Amd India Private Limited, Bengaluru vs Acit, Circle-1(1)(1), Bangalore on 26 June, 2023

v. DCIT (reported in [2020] 116 taxmann.com 421 (Bangalore - Trib.)) and the decision of the Hyderabad Bench of this Tribunal in EPAM Systems India (P.) Ltd. v. ACIT (reported in [2018] 100 taxmann.com 335 (Hyd-Trib), where in the cases of similarly placed assessees, the company was directed to be excluded. In IT(TP)A Nos.1858 & 2031/Bang/2024 AMD India Pvt. Ltd., Bangalore Page 32 of 47 view of the above, she submitted that this company ought to stand excluded from the final list of comparables. 7. The ld. D.R. relied on the order of ld. DRP.
Income Tax Appellate Tribunal - Bangalore Cites 68 - Cited by 4 - Full Document

Mid East Port Folio Management Ltd. vs Deputy Commissioner Of Income Tax ... on 14 August, 2003

16. Therefore the test for a benefit to be taxed under section 28(iv) as laid down in the above decision is that the benefit should irretrievable and that the benefit is received with an intention to circumvent income. For example a person is selling a product at a discounted price and is getting a gift or other benefit from the purchaser then the value of such gift or benefit is to be treated as business income under section 28(iv) since the benefit received has a direct nexus to the discounted price which is shown as the business income.
Income Tax Appellate Tribunal - Mumbai Cites 77 - Cited by 98 - Full Document
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