ACCENTURE SERVICES P.LTD,MUMBAI vs. DCIT CIT 14(1)(1), MUMBAI
What did the Tribunal hold?
The Tribunal held that I-Gate Global Solutions Limited cannot be accepted as a comparable for benchmarking the ITeS segment due to the non-availability of segmental data. The Assessing Officer/TPO is directed to exclude it and re-compute the ALP.
What were the facts?
This is a corrigendum to a previous ITAT order. It corrects the name of the appellant and a comparable company mentioned in the original judgment. The core issue relates to the exclusion of a comparable company for transfer pricing benchmarking.
What were the issues?
The primary issue is the appropriateness of using I-Gate Global Solutions Limited as a comparable for transfer pricing purposes due to data limitations.
Which sections of the Income-tax Act were involved?
Not explicitly mentioned in the corrigendum, but the context implies transfer pricing provisions.
AI-generated summary — verify with the full judgment below
Heard together (3 matters)
Read from the judgment's own cause title. This page is filed under one of them.
CORRIGENDUM In the order, dated 11/07/2023, passed by “K” Bench of the Tribunal 1. in Appellant has been incorrectly mentioned in the cause title as :
Accenture Services Private Limited [as a successor to Accenture Services Private Limited („ASPL‟) which has merged into ASOL with an effective date of 01 December 2016] 1.1. The name of the Appellant as mentioned in the cause title shall be replaced by and read as the following name stated in Form 36B, dated 29/09/2017:
Accenture Solutions Private Limited (ASOL) [as a successor to Accenture Services Private Limited („ASPL‟) which has merged into ASOL with an effective date of 01 December 2016]
Corrigendum: (Assessment Year: 2011-2012) Further, after quoting the decision of the Tribunal in the case of 2. Goldman Sachs Services Pvt. Ltd. Vs. DCIT: [ITA No. 581/Bang/2016] & C.O. 21/Bang/2017, dated 12/09/2018, in paragraph 5.12 of the decision, in paragraph 5.13 the name of comparable has been incorrectly mentioned as „Goldman Sachs Services Pvt. Ltd.‟ instead of „I-Gate Global Solutions Limited‟. Therefore, „Goldman Sachs Services Pvt. Ltd.‟ stated in paragraph 5.13 shall stand replaced by and be read as ‟I-Gate Global Solutions Limited.‟ Accordingly, paragraph 5.13 shall read as under:
5.13 In the above appeal, the Tribunal had upheld the decision of the DRP to exclude I-Gate Global Solutions Limited as a comparable for benchmarking ITeS Segment as segmental data for IT Services and ITeS Services was not available in the annual financial statements of I-Gate Global Solutions Limited. Thus, facts/contentions being identical, respectfully following the above decision of the Co-ordinate Bench of the Tribunal, we hold that for the Assessment Year 2011-12, I-Gate Global Solutions Limited cannot be accepted as comparable in the present case on account of non-availability of segmental data. Accordingly, the Assessing Officer/TPO are directed to exclude the I-Gate Global Solutions Limited from the final set of comparables and re-compute ALP as well as transfer pricing adjustment, if any, accordingly.
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