rejecting the comparable
viz. 1. Larsen Turbo InfoTech Ltd. 2. Persistent Systems Ltd,
3.Sasken Communication Technologies Ltd., 4. Zylog Systems
Ltd., 5. Wipro Technologies ... 2017
Persistent has undergone extra ordinary events during the year
under assessment as it has amalgamated with Persistent eBusiness
Solutions Ltd. and Persistent Systems
Infosys BPO Limited
Sasken Communication Aditya Birla Minnacs Worldwide
Technologies Limited
Persistent Systems Limited Accentia Technologies Limited
Larsen & Toubro Infotech Informed Technologies India Limited ... Systems Ltd (seg), Helios & Matheson Information
Technology Ltd, Infosys Technologies Ltd, Ishir Infotech Ltd, Kals Information
Systems Ltd (seg), Lucid software Ltd, Persistent Systems
Omni Ax'S Software Ltd. 2
8 Persistent Systems & Solutions Ltd 20
9 Quinnox Consultancy Services Ltd. 14
10 Reliance Infosolutions ... comparables and retained only
two comparables, namely, Mindtree Ltd and Persistent Systems &
IT(TP)A.356 & 313/Bang/2016 Page - 5
Solutions
thereby
implying to uphold the actions of the TPO to include Persistent
Systems Limited as a comparable to the Appellant. Whereas this
company should have ... assessee's appeal, another comparable i.e. Persistent Systems
Ltd. should be excluded from the list of final comparables. Regarding the
assessee
Limited, ICRA Techno Analytics Limited, Infosys Limited, Tata Elxsi
Limited and Persistent Systems and Solutions Limited as comparable
companies applying unreasonable comparability criteria.
Paragraph ... companies.
3. Re: Ground No. 17: Larsen & Toubro Infotech Limited, Persistent Systems
Limited and Sasken Communication technologies Limited were chosen as
comparables in transfer
Transfer Pricing issue and the assessee had sought
exclusion of Persistent Systems and Solutions Lt d., from the
final list of comparables. It is submitted ... that the Tribunal, in
para 9 of its order, directed that Persistent Systems Ltd be
excluded instead of Persistent Systems and Solutions Limited.
Thus, according
arguments put forth in relation to a comparable
i.e. 'Persistent Systems Limited' in the aforementioned impugned
M.P. No. 164/Bang/2018 ... Tribunal that the Applicant was arguing
for exclusion of 'Persistent Systems Limited'. Even the Hon'ble
Tribunal in internal page
Information Systems Limited (Seg.) 2.05
7. LGS Global Limited 136.52
8. Lucid Software Limited 2.35
9. Quintegra Solution Limited 89.88
10. R Systems International ... 1070/Bang/2013
Page 23 of 51
vi. Persistent Systems Ltd.
vii. Quintegra Solutions Ltd.
viii. Tata Elxsi Ltd. (seg)
ix. Thirdware Solutions
Global Ltd. 14.11%
11 Mindtree Ltd. 10.29%
12 Persistent Systems & Solutions Ltd. 21.51%
13 Persistent Systems Ltd. 23.08%
14 R S Software (India ... Global Ltd 12.42%
11 Mindtree Ltd 10.29%
12 Persistent Systems & Solutions Ltd 22.24%
13 Persistent Systems Ltd 22.82%
12
14 R S Software (India
order, he retained only one company, namely, M/s Persistent
Systems Ltd. and chose three new companies, namely, Infosys
Technologies, E-Infochips Bangalore and Wipro ... fact, the TPO shortlisted four companies,
including Persistent Systems Ltd., which was assessee's comparable. The
assessee has assailed the inclusion
