relating to Software or Special Value Products; plus
(f) a percentage of the Net Selling Value (Software), as set forth in Appendix C hereto ... operations relating to Software; plus
(g) compensation for Special Value Product(s), as set forth in Appendix B hereto, in a separate agreement among
this year also. We are inclined to concur with the argument put forth by
the assessee that Infosys Technologies Ltd is not functionally comparable since ... activity, brand value, size,
etc. The TPO, however, rejected the contention put forth by the assessee and
included this company in the set of comparables
M/S Pmc Sierra India Pvt. Ltd.,, vs Department Of Income Tax on 26 August
this year also. We are
inclined to concur with the argument put forth by the assessee that Infosys
Technologies Ltd is not functionally comparable since ... activity, brand value, size, etc. The TPO, however, rejected the contention put
forth by the assessee and included this company in the set of comparables
activity, brand value, size, etc. The TPO,
however, rejected the contention put forth by the assessee and
included this company in the set of comparables
Tesco Hindustan Service Centre Private ... vs Dcit, Bangalore on 9 December, 2016
IN THE INCOME
conditions set-forth as per Explanation-3 to Section 43(1)
of the I.T. Act, are satisfied, he has adopted the value
company i.e. Persistent
Systems Ltd. ought to be omitted from the set of comparables for the year
under consideration. It is ordered accordingly ... activity, brand value, size, etc. The TPO,
however, rejected the contention put forth by the assessee and
included this company in the set of comparables
Call Value, subject to any regulatory approval",
(iv) By Article 3.3 states:
"(i) To exercise the right set forth in Article 3.1 ,
Barings ... Upon receipt of the Call Notice and payment of the Call
Value, the Purse Shareholders shall be obligated to
transfer the Shares to Barings within
Microchip Technology (India) Private ... vs Assessee on 31 October, 2016
IN THE INCOME TAX APPELLATE
