higher compared to the preceding years
and due to increase in the turnover, the semi-variable expenses increase
gradually and there is slight difference between ... assessee. Therefore, the saving
in semi-variable expenses will compensate the decrease/increase in the
profit which is very much less in percentage as noted
Acer India Pvt Ltd, Bengaluru vs Deputy Commissioner Of Income Tax, ... on 5 March, 2020
raised by assessee is in respect of application of
upper limit of turnover in respect of following comparables and
seeking its exclusion.
a) Infosys ... limit on the turnover while selecting the companies
comparable to the assessee. In this regard, it is submitted that
application of turnover filter
crores turnover filter. The Ld.AR filed the following details in
respect of the comparables for which the upper turnover filter
has not been applied ... upper limit on the turnover while selecting the companies
comparable. In this regard, it is submitted that application of
turnover filter is relevant criterion
open market and not because the working capital cost increases or decreases the profit margin.
Hence we find no merit in this claim ... comparables are to be excluded.
(i) Infosys BPO Limited - where the turnover is Rs.1,312 Crores and has a global
brand value with
that out of 11 comparable companies chosen by the TPO, the turnover
of Infosys Ltd., L&T, Mindtree Ltd., Persistent Systems Ltd., Sasken
Communication ... assessee with the
following observations:-
"10.65 Turnover Filter: The TPO had applied the turnover
filter with Rs. 1 crore at the lower
comparables deserves to
be excluded on application of upper turnover filter.
Sl. Turnover
Name of the Company
No. (in crores)
1 Exilant Technologies ... upper limit on the turnover while selecting the companies
comparable. In this regard, we note that, application of turnover
filter is a relevant criterion
also drew attention of this bench to a table
wherein the turnover of the comparables were listed in the
decision relied by him in case ... upper
limit on the turnover while selecting the companies comparable.
In this regard, it is submitted that application of turnover filter is
relevant criterion
Aztec Software And Technology Service ... vs Acit on 12 July, 2007
Equivalent citations: [2007]107ITD141
M/S Innoviti Payment Solutions Pvt Ltd , ... vs The Income Tax Officer Circle-3(1
