excluded this company on the ground that it
failed export turnover filter of 75% but the TPO had not raised any
objection regarding the functionally ... companies with huge turnover have been incorrectly
accepted in the final set of comparables.
Erroneous application of 'export to turnover filter
rejected the aforesaid three companies as comparables by
applying the export turnover filter. Apart therefrom, the TPO being of
the view that the assessee ... Management Consulting Services
Ltd. had low export earnings of 9.3%, hence the same failed the export
turnover filter of 75% and thus could not have
Revenue that the export sales to turnover of this company is 92% and
therefore passes the test of export turnover filter being at least ... Revenue that the export sales to turnover
of this company is 98% and therefore passes the test of export turnover filter being at
least
bench wherein it was found that this company failed the export
turnover filter of 75% of the total turnover. He has further contended that ... which is to the effect that the said concern fails the export
turnover filter of 75% of the total turnover."
53. Having regard
granted relief with regard to this comparable as it
failed in Export Turnover Filter. TPO considered only total export of 14% of
the total turnover ... turnover).
3. Company is engaged into provisions of ITes.
Held by CIT(A): Company is to be excluded as it fails export turnover filter.
Assessee
comparable to the Appellant on the following grounds:
a. Applying export turnover filter of less than equal to
30% of the sales and disregarding export ... domestic market and is having negligible export sales.
Following companies does not qualify the export turnover
filter of less than equal to 10% of total
turnover
whereas income of tested party is 100% from exports. Accordingly this
company is to be excluded on the basis of 75% export turnover filter ... turnover whereas income of tested party is 100% from exports. Accordingly
this company is to be excluded on the basis of 75% export turnover filter
clients.
Export turnover filter
has already been
removed by this
office.
High turnover -
The applicability
of turnover filter
has already been
discussed earlier
in Para ... company. It is a
good comparable.
Fails to export income
filter of greater than Export turnover filter
75% of total service has already been
income
Media Research Users
Council, Apitco Limited, Global Procurement Consultants Limited failed export
turnover filter. The DRP only upheld the inclusion of Info Edge (India) Limited ... functionally different and segmental details are not
available. Further, it fails export turnover filter being 14.16%. We, therefore,
uphold the order
fails the export revenue filter. While the assessee demonstrated before the DRP that
the company passes the filter and earned revenue from export of services ... export revenue filter and the filters applied by the DRP, because admittedly the assessee
was not confronted by the DRP on the new filter
