COMPUTERLAND UK LIMITED,PUNE vs. ASSISTANT COMMISSIONER OF INCOME-TAX, (IT)-1, PUNE

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ITA 2505/PUN/2017Status: DisposedITAT Pune06 December 2021AY 2013-1428 pages
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What did the Tribunal hold?

The tribunal held that Megri Soft Ltd. was functionally dissimilar to the assessee and directed its exclusion from the set of comparable companies. Other grounds were either not pressed or rendered infructuous.

What were the facts?

The assessee, ComputerLand UK Limited, appealed against the transfer pricing adjustment made by the revenue for the assessment year 2013-14. The core of the dispute involved the selection and rejection of comparable companies for benchmarking the provision of IT services.

What were the issues?

The primary issues concerned the appropriateness of transfer pricing adjustments, the selection and rejection of comparable companies, and the application of filters and adjustments in the benchmarking analysis.

Which sections of the Income-tax Act were involved?

Section 144C,Section 271(1)(c),Section 234B

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Income Tax Appellate Tribunal, “C” BENCH, PUNE

Before: SHRI R.S.SYAL, VP & SHRI PARTHA SARATHI CHAUDHURY, JM

For Appellant: Shri Rajendra Agiwal
For Respondent: Shri Rajiv Kumar
Hearing: 01.12.2021Pronounced: 06.12.2021

आदेश की प्रधतधलधप अग्रेधषत / Copy of the Order forwarded to : अपीलाथी / The Appellant. 1. प्रत्यथी / The Respondent. 2. 3. The CIT(Appeals)-13, Pune. 4. The Pr. CIT-5, Pune. धवभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, “सी” बेंच, 5. पुणे / DR, ITAT, “C” Bench, Pune. गार्ा फ़ाइल / Guard File. 6.

आदेशानुसार / BY ORDER, // True Copy // धनजी सधचव / Private Secretary आयकर अपीलीय अधधकरण, पुणे / ITAT, Pune.

Date 1 Draft dictated on 01.12.2021 Sr.PS/PS 2 Draft placed before author 06.12.2021 Sr.PS/PS 3 Draft proposed and placed JM/AM before the second Member 4 Draft discussed/approved by AM/JM second Member 5 Approved draft comes to the Sr.PS/PS Sr. PS/PS 6 Kept for pronouncement on Sr.PS/PS 7 Date of uploading of order Sr.PS/PS 8 File sent to Bench Clerk Sr.PS/PS 9 Date on which the file goes to the Head Clerk 10 Date on which file goes to the A.R 11 Date of dispatch of order

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