“comparable companies”

Transfer PricingSection 92CSection 92C1,304 judgments

The decision most relied on for comparable companies is Rampgreen Solutions Pvt. Ltd. v. CIT (377 ITR 533), cited in 196 judgments on BharatTax.

Leading authorities on comparable companies

Rampgreen Solutions Pvt. Ltd. v. CIT

377 ITR 533 · 2015 · High Court

196

citing judgments

Knowledge Process Outsourcing (KPO) service providers are functionally dissimilar to Business Process Outsourcing (BPO) or Information Technology Enabled Services (ITeS) providers and cannot be compared for transfer pricing purposes, even under the Transactional Net Margin Method (TNMM). Further, companies with significantly different business models, such as those with extensive subcontracting, should be excluded as comparables.

DCIT v. Quark Systems (P.) Ltd.

38 SOT 307 · 2010 · ITAT

179

citing judgments

An assessee is not estopped or precluded from seeking the exclusion of a company from its Transfer Pricing study comparables, even if initially selected, if it can demonstrate valid reasons for non-comparability.

CIT v. Agnity India Technologies (P.) Ltd.

36 Taxmann.com 289 · 2013 · High Court

171

citing judgments

The Delhi High Court holds that Infosys Ltd. is not comparable to a captive software development service provider for transfer pricing analysis, given its huge turnover, high profit margins, ownership of intangible intellectual property rights, branded products, and differing risk profile.

Chryscapital Investment Advisors (India) Pvt. Ltd. v. DCIT

376 ITR 183 · 2015 · High Court

170

citing judgments

For transfer pricing comparability analysis, companies should not be excluded solely based on higher turnover if they are otherwise functionally comparable, unless the turnover difference reflects fundamental functional dissimilarities, brand value, or risk profiles that materially impact profitability.

Autodesk India Pvt.Ltd. v. DCIT

96 Taxmann.com 263 · 2018 · ITAT

116

citing judgments

A high turnover criterion, such as above Rs. 200 crores, is a valid ground to exclude companies from the list of comparable companies in a transfer pricing analysis, as such companies are not comparable to those with significantly lower turnover.

SAP Labs India Pvt. Ltd. v. ACIT

44 SOT 156 · 2011 · ITAT

100

citing judgments

Foreign exchange fluctuation gains or losses are operational in nature and must be included in the computation of the operating margin for both the assessee and comparable companies when determining the Arm's Length Price.

Mentor Graphics (Noida) (P) Ltd. v. DCIT

109 ITD 101 · 2007 · ITAT

citing judgments

A working capital adjustment is mandated and a prerequisite for correctly determining the Arm's Length Price (ALP) under Rule 10B(1)(e) and Rule 10B(3) of the Income Tax Rules, 1962. This adjustment accounts for differences in working capital and outstanding receivables between the assessee and comparable companies.

Avenue Asia Advisors Pvt. Ltd. v. DCIT

398 ITR 120 · 2017 · High Court

citing judgments

The Delhi High Court holds that a detailed functional and working capital analysis, considering various factors, is essential before treating outstanding receivables as a separate international transaction for transfer pricing adjustments on notional interest. Simply making an adjustment based on receivables alone without such study distorts the transaction's character.

Judgments citing comparable companies

L'Oreal India Private Limited, Mumbai vs. Income Tax Department, Mumbai

ITA 4577/MUM/2024[2020-21]Status: DisposedITAT Mumbai16 Dec 2024AY 2020-21

Bench: Shri Sandeep Gosain & Shri Prabhash Shankarl'Oreal India Private V/S. Assistant Commissioner Of Limited, A-Wing, 8Th Floor, Marathon Futurex, N.M. Joshi Marg, Lower Parel, Mumbai Maharashtra 400 013, बनाम Income Tax- 7(1)(1), Aayakar Bhavan, M.K. Road, Mumbai 400020, Maharashtra स्थायी लेखा सं./जीआइआर सं./ Pan/Gir No: Aaacl0738K Appellant/अपीलार्थी .. Respondent/प्रतिवादी Appellant By : Shri Niraj Sheth Respondent By : Ms. Neena Jeph (Cit Dr) Date Of Hearing 19.11.2024 Date Of Pronouncement 16.12.2024 आदेश / Order Per Prabhash Shankar [Α.Μ.] This Is An Appeal Filed By The Assessee, Challenging The Assessment Order Passed By The Assessing Officer/Transfer Pricing Officer (‘Tpo' For Short) Pursuant To The Direction Of The Hon'Ble Dispute Resolution Panel ('Drp' For Short), Passed U/S. 143(3) R.W.S. 144C(13) R.W.S. 144B Of The Act Relevant To The Assessment Year (A.Y. For Short) 2020-21.The Assessee Has Challenged The Grounds Of Transfer Pricing Adjustment On Account Of Advertisement, Marketing & Promotion (Amp) Expenses. Following Are The Grounds Raised By The Assessee: Page 2

For Appellant: Shri Niraj ShethFor Respondent: Ms. Neena Jeph (CIT DR)

Section 143(3)Section 4Section 92Section 92BSection 92C

entrepreneurial business activities into manufacturing and distribution segment without any cogent reasons for the same and arbitrarily and in an adhoc manner selecting comparable companies for manufacturing and distribution segment without adopting a scientific search process for applying bright line test

International Packaging Products Private Limited, Mumbai vs. Deputy Commissioner of Income Tax Circle 2(1)(1), Mumbai

In the result, appeal of the assessee is partly allowed for statistical purposes

ITA 4225/MUM/2024[2020-21]Status: HeardITAT Mumbai16 Dec 2024AY 2020-21

Bench: Us, Following Grounds Of Appeal Have Been Pressed: -

Section 234CSection 92C

comparable having segmental accounts (Polyspin Export Limited and Commercial Syn Bags Limited) in parity with the margin calculated for the Appellant and other comparable companies." "4.1 On the facts and circumstances of the case and in law, the Ld. AO erred in restricting MAT credit ... applied TNMM as Most Appropriate Method. Assessee had shortlisted 23 comparables and held that the range of weighted average of OP/OC of the comparable companies is 1.34% to 3.95% with a median of 3.38%. Whereas, the assessee has calculated its OP/OC at 5.24% from exports to AE and stated that

Letiwind Shriram Manufacturing Limited, Chennai vs. DCIT, Chennai

In the result, the appeal filed by the assessee is dismissed

ITA 493/CHNY/2017[2012-13]Status: DisposedITAT Chennai13 Dec 2024AY 2012-13

Bench: Shri Ss Viswanethra Ravi & Shri Jagadishआयकर अपील सं./Ita No.493/Chny/2017 िनधा;रण वष; /Assessment Year: 2012-13

For Appellant: NoneFor Respondent: Shri A. Sasikumar, CIT

Section 143(3)

raised by the assessee are as under: “1. The learned TPO and the Dispute Resolution Panel erred in rejecting M/s.RRB Energy Limited as a comparable company, despite being functionally comparable to the assessee. 2. The learned TPO and the Dispute Resolution Panel erred on facts and circumstances in proposing ... considering appropriate adjustments under Rule10B of the Income Tax Rules, 1962 (The Rules) to account for the economic differences between the Assessee and the comparable companies. 5. For the above grounds and for any other grounds that may be adduced at the time of hearing, the appellant prays

Robert Bosch Engineering and Business Solutions Private Limited, Bengaluru vs. The Joint Commissioner of Income Tax, Large Tax Payers Unit, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 593/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing

Section 115Section 115JSection 237Section 80J

OP/OC) ratio as the Profit Level Indicator (PLI). The assessee selected a different set of comparables for both segments and determined the PLI of comparable companies by considering the weighted average margin of three years' data. The assessee calculated the PLI of the comparable companies at 17.59% for the Software ... Software Development Segment as being at ALP. However, the TPO rejected the assessee's TP analysis for the ITES Segment. The TPO disqualified the comparable companies selected by the assessee, citing the following reasons: i. The use of non-current year data. ii. Improper application of the export turnover filter

Deputy Commissioner of Income Tax, Circle- 2, Ltu, Bengaluru vs. M/S. Robert Bosch Engineering and Business Solutions Private Limited, Bangalore

In the result, the appeal of the Revenue is hereby dismissed

ITA 446/BANG/2020[2012-13]Status: DisposedITAT Bangalore09 Dec 2024AY 2012-13

Bench: Shri Waseem Ahmed & Shri Soundararajan K

For Appellant: Shri Sridhar E, CIT (DR)For Respondent: Date of hearing

Section 115Section 115JSection 237Section 80J

Goldman Sachs (India) Securiteis Private Limited, Mumbai vs. Add/Jt/Dy/Asst/CIT/ITO/NFAC, Delhi

ITA 763/MUM/2022[2017-18]Status: DisposedITAT Mumbai09 Dec 2024AY 2017-18

Bench: Shri Amarjit Singhshri Sandeep Singh Karhail

For Appellant: Shri Madhur AgrawalFor Respondent: Ms. Neena Jeph, CIT-DR

Section 143(3)Section 144BSection 144C(13)Section 144C(5)Section 253(1)Section 92C

Cherry picking and not following a scientific search process in identifying companies and not providing the search criteria/ strategy adopted for identifying such additional comparable companies; c) Rejecting the following functionally similar companies selected as comparables by the Appellant in the transfer pricing documentation: Sundaram Business Services Limited • Microland Limited ... Technologies India Limited and Suprawin Technologies Limited, by applying turnover filter; g) Rejecting Informed Technologies Limited, on account of negative margin earned by the comparable company; h) Considering MPS Limited, as comparable companies to the Assessee without recording the reason for rejecting Assessee's contentions as submitted during

Concur Technologies (India) Private Limited, Bengaluru vs. Assistant Commissioner F Income Tax Circle 2(2)(1), Bengaluru

In the result, the appeal of the assessee is allowed for statistical purposes

ITA 1925/BANG/2024[2020-2021]Status: DisposedITAT Bangalore05 Dec 2024AY 2020-2021

Bench: Shri Prashant Maharishi & Shri Keshav Dubey

For Appellant: Shri Chavali Narayan, CAFor Respondent: Ms. Neera Malhotra, CIT(DR)(ITAT), Bengaluru

Section 143(3)Section 144C(5)Section 92B

payables or net working capital days. For AY 2020-21, Appellant's average net working capital days was negative 10 days as compared to comparable companies average net working capital days of 76 days. 6. Without prejudice to Appellant contentions that the outstanding receivables should not be treated ... international transaction, the TPO erred in law and facts by not comparing Appellants average receivables period as against the average receivables period of the comparables companies. For AY 2020-21, Appellant's average receivable period was 40 days as compared to comparable companies average receivable period of 159 days

Iljin Automotive Private Limited, Kanchipuram vs. DCIT Corporate Circle 2(2), Chennai

The appeal stand partly allowed in terms of our above order

ITA 1834/CHNY/2017[2013-14]Status: DisposedITAT Chennai03 Dec 2024AY 2013-14

Bench: Hon’Ble Shri Manoj Kumar Aggarwal, Am & Hon’Ble Shri Manu Kumar Giri, Jm आयकरअपील सं./ Ita No.1834/Chny/2017 (िनधा)रणवष) / Assessment Year: 2013-14) M/S. Iljin Automotive Private Limited Dcit बनाम/ Plot No.B1 & B2, Sipcot Industrial Park Corporate Circle-2(2), Irungattukottai, Sriperumbudur Chennai. Vs. Kanchipuram-602 105. "थायीलेखासं./जीआइआरसं./Pan/Gir No.Aaaci-2641-E (अपीलाथ"/Appellant) : (" थ" / Respondent) अपीलाथ"कीओरसे/ Appellant By : Shri Sandeep Bagmar (Advocate) - Ld. Ar " थ"कीओरसे/Respondent By : Shri A. Sasikumar (Cit) - Ld. Dr सुनवाईकीतारीख/Date Of Hearing : 19-11-2024 घोषणाकीतारीख /Date Of Pronouncement : 03-12-2024 आदेश / O R D E R

For Appellant: Shri Sandeep Bagmar (Advocate) - Ld. ARFor Respondent: Shri A. Sasikumar (CIT) - Ld. DR

Section 143(3)Section 144C(5)Section 32Section 43ASection 92CSection 92C(3)

facts in rejecting the usage of multiple year data for comparability analysis. 2.3 Erred in law and on facts by rejecting comparable companies selected by the Appellant in the transfer pricing documentation. Further, erred in rejecting comparable companies whose products are broadly comparable to that of the Appellant. Erred ... facts by disregarding the rule of consistency and rejecting comparable companies which were consistently selected and accepted by the Ld. TPO year on year. 2.4 Erred in law by selecting a company having significant related party transaction as a comparable company. 2.5 Erred in law by selecting companies which

United Futuristic Trade Impex Private Limited, Mumbai vs. Commissioner of Income-Tax (Appeals), National Faceless Appeal Centre (NFAC)

In the result, the present cross-appeal is allowed for statistical purposes

ITA 4219/MUM/2024[2017-2018]Status: DisposedITAT Mumbai29 Nov 2024AY 2017-2018

Bench: Shri Om Prakash Kantshri Sandeep Singh Karhailacit, Circle – 8(3)(1) Room No.665A, 6Th Floor, Aayakar Bhavan, Mumbai – 400020 ............... Appellant V/S United Futuristic Trade Impex Pvt. Ltd., Unit No.301, 3Rd Floor, Turf Estate Off Dr. E Moses Road, Shakti Mill Lane Mahalaxmi, Mumbai – 400011, ……………… Respondent Maharashtra Pan : Aabcu7296C United Futuristic Trade Impex Pvt. Ltd., Bajaj Bhavan, 226-Nariman Point, Unit No.301, 3Rd Floor, Turf Estate Off Dr. E Moses Road, Shakti Mill Lane Mahalaxmi, Mumbai – 400011, Maharashtra ……………… Appellant Pan : Aabcu7296C V/S Acit, Circle – 8(3)(1) Room No.665A, 6Th Floor, Aayakar Bhavan, Mumbai – 400020 …………….. Respondent

For Appellant: Shri Satish ModyFor Respondent: Shri Raj Singh Meel, Sr. DR

Section 250

material to substantiate the basis? 2. Whether the Ld. CIT (A) erred in ignoring the fact that the AO has brought on record the comparable companies to estimate the net profit at 5.59% of the total turnover for the year concerned as business income of the assessee and the same

ACIT Circle 8(3)(1), Mumbai vs. United Futuristic Trade Impex Pvt. Ltd., Mumbai

In the result, the present cross-appeal is allowed for statistical purposes

ITA 3674/MUM/2024[2017-18]Status: DisposedITAT Mumbai29 Nov 2024AY 2017-18

For Appellant: Shri Satish ModyFor Respondent: Shri Raj Singh Meel, Sr. DR

Section 250

Otis Elevator Company (India) Limited, Mumbai vs. DCIT, 13(1)(2), Mumbai

ITA 3337/MUM/2024[2020-21]Status: DisposedITAT Mumbai29 Nov 2024AY 2020-21

Bench: Shri Narendra Kumar Billaiya, Hon'Ble & Shri Sunil Kumar Singh, Hon'Bleι.Τ.Α. No. 3337/Mum/2024

For Appellant: Shri Rajan Vora & Nikhil Tiwari, A/RsFor Respondent: Shri Asif Karmali, Sr. D/R

Section 143(3)Section 144C(13)Section 234ASection 234CSection 234FSection 270A(1)Section 37(1)Section 92CSection 92C(3)

similar regions. 6.3. Further a secondary analysis is conducted using combined TNMM approach. The assessee is a tested party wherein operating margins earned by comparable companies ranges from (-)1.31% to 7.65% with a median of 5.76% on operating revenue whereas the assessee has earned an operating margin

ACIT-5(1)(1), Mumbai vs. Ankit Gems Pvt.Ltd., Mumbai

In the result, Revenue’s appeal is dismissed

ITA 2579/MUM/2024[2013-14]Status: DisposedITAT Mumbai29 Nov 2024AY 2013-14

Bench: SHRI OM PRAKASH KANT (Accountant Member), MS. KAVITHA RAJAGOPAL (Judicial Member)

For Appellant: Shri Sanjay ChokshiFor Respondent: Ms. Neena Jeph

Section 250Section 271GSection 92CSection 92DSection 92D(3)

using operating profit/sales as Profit Level Indicator (PLI). The assessee had taken the margin at entity level and had compared the transactions with the comparable companies and determined the transactions at arm’s length price. The ld. AO/TPO sought for details of segmental financials of the purchase and sales transactions

Deputy Commissioner of Income-Tax, Circle - 5, Pune vs. Renishaw Metrology Systems Ltd, Pune

The appeal of the Revenue is partly allowed for statistical purposes in above terms

ITA 628/PUN/2021[2013-14]Status: DisposedITAT Pune26 Nov 2024AY 2013-14

Bench: Hon’Ble Smt Astha Chandra, Judical Member & Shri G. D. Padmahshaliआयकर अपील सं. / Ita No. 0628/Pun/2021 िनधा"रण वष" / Assessment Year : 2013-14 Dy. Commissioner Of Income Tax, Central Circle-5, Pune . . . . . . . अपीलाथ" / Appellant

For Appellant: Mr Ajit Jain [‘Ld. AR’]For Respondent: Mr Manish Mehta [‘Ld. DR’]

Section 143(2)Section 143(3)Section 246A(1)Section 250Section 253(2)Section 92C

ITAT-Pune Page 5 of 10 DCIT Vs Renishaw Metrology Systems Ltd. ITA No. 628/PUN/2021 AY: 2013-14 through the financial statements of these comparable companies. It is further submitted that, in the absence of change in the functionality and size & scale of operation of these comparable ... concerned, we note that at the time of proposed TP proposed adjustment and at first appellate proceeding not only functionality difference of this comparable company was at a challenge, but the size & scale of operation. ITAT-Pune Page 6 of 10 DCIT Vs Renishaw Metrology Systems Ltd. ITA No. 628/PUN/2021

Benu Networks Packet Switch Private Limited, Hyderabad vs. DCIT, Circle -1 (2), Hyderabad

In the result, appeal filed by the assessee is allowed for statistical purposes

ITA 86/HYD/2022[2017-18]Status: DisposedITAT Hyderabad25 Nov 2024AY 2017-18

Bench: Shri Vijay Pal Rao, Vice-A N D Shri Manjunatha, G. & आ.अपी.सं /Ita No.86/Hyd/2022 (िनधा"रण वष"/Assessment Year: 2017-18) Benu Networks Packet Switch Vs. Dy. Commissioner Of Income Tax, Circle 1(1) Private Ltd, Hyderabad Hydrabad Pan:Aaecb4902B (Appellant) (Respondent) िनधा""रती "ारा/Assessee By: Shri Ashish Jain, Ca राज" व "ारा/Revenue By:: Shri B Balakrishna, Dr सुनवाई की तारीख/Date Of Hearing: 13/11/2024 घोषणा की तारीख/Pronouncement: 25/11/2024 आदेश/Order

For Appellant: Shri Ashish Jain, CAFor Respondent: : Shri B Balakrishna, DR

Section 143(3)Section 144C(5)Section 92B

Benu Networks Packet Switch P Ltd Ground No.1 The learned TPO has erred by rejecting the following 7 comparable companies in the software development segment selected/accepted by the assessee on unjustifiable grounds even though sufficient data was available, and they were functionally comparable to the assessee and satisfied ... appeal.” 3. Ground No.1 is general in nature and does not require any specific adjudication. 4. Ground No.2 is regarding rejection of 7 comparable companies selected by the assessee in its TP study analysis. The assessee company is engaged in the business of providing software development services

DCIT 1 (1)(2), Mumbai vs. M/S Hindustan Unilever Ltd., Mumbai

In the result, the appeal filed by the assessee and Revenue are partly

ITA 6913/MUM/2019[2005-06]Status: DisposedITAT Mumbai14 Nov 2024AY 2005-06

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Nishant Thakkar a/wFor Respondent: Shri Azhar Zain Vayal Parambath

Section 80HSection 80I

bench marked the international transactions at entity level. The margin of the assessee was within the tolerance limits vis-a-vis the margin of comparable companies. The TPO did not accept entity level bench marking and accordingly, proceeded to make Transfer Pricing adjustment in respect of each of the international ... entity level TNMM as the most appropriate method. b. The operating margin of the Assessee was arrived at 11.91%. The arithmetical mean of the comparable companies selected by the Appellant Assessee worked out to 10.38%. In the circumstances, the Assessee contended that its transactions were at length

Hindusthan Unilever Ltd, Mumbai vs. Dy CIT Range 1(1)(2), Mumbai

In the result, the appeal filed by the assessee and Revenue are partly

ITA 6783/MUM/2019[2005-06]Status: DisposedITAT Mumbai14 Nov 2024AY 2005-06

Bench: Justice (Retd.) Shri C.V. Bhadang & Shri B.R. Baskaran

For Appellant: Shri Nishant Thakkar a/wFor Respondent: Shri Azhar Zain Vayal Parambath

Section 80HSection 80I

Imsofer Manufacturing India Pvt. Ltd., Pune vs. ACIT, Circle-12(1), New Delhi

In the result, the appeal of the assessee in ITA No

ITA 7923/DEL/2019[2012-13]Status: DisposedITAT Delhi14 Nov 2024AY 2012-13

Bench: Shri Challa Nagendra Prasad & Shri Naveen Chandra

For Appellant: Shri Ajit Jain, ARFor Respondent: Shri Reuben Mathew Jacob, Sr. DR

Section 92C(2)Section 92D

further erred in upholding/confirming the action of the Ld. TPOI AO by: 2.1 disregarding the benchmarking analysis and comparable companies selected by the Appellant based on the contemporaneous data in the transfer pricing study report maintained as per Section 92D of the Act read with Rule 10D of the Income ... Rules'). 2.2 following inconsistent approach while selecting the comparable during the current year vis-a-vis previous assessment year and rejecting the functionally comparable companies without considering the judicial precedents submitted by the Appellant. 2.3rejecting comparable companies selected by the appellant in its TP Study on inappropriate grounds although

Cognizant Technology Solutions India Private Limited(Erstwhile Excellence Data Research Private Limited), Chennai vs. Asst. Commissioner of Income Tax, Central Circle-17(1), Hyderabad

In the result, appeal of the assessee is partly allowed

ITA 13/HYD/2018[2013-14]Status: DisposedITAT Chennai08 Nov 2024AY 2013-14

Bench: Shri Aby T. Varkey & Shri Amitabh Shuklaआयकर अपील सं./Ita No.13/Hyd/2018 िनधा"रण वष"/Assessment Year: 2013-14 V. M/S. Cognizant Technology- The Acit, Solutions India Pvt. Ltd., Circle-17(1), 9Th Floor, (As Successor In Interest Of Erstwhile Excellence Data Signature Towers, Opp: Botanical Garden, Research Pvt. Ltd.), 6Th Floor, New No.165, Old No.110, Kondapur, Hyderabad. Menon Eternity Building, St. Mary’S Road,Alwarpet, Chennai-600 018. [Pan: Aabce 4933 C] (अपीलाथ"/Appellant) (""यथ"/Respondent)

For Appellant: Mr. S.P.Chidambaram, AdvFor Respondent: Ms. C. Vatchala, CIT

Section 143(3)Section 144C(5)Section 92C

compliance with Accounting Standard-15 regarding provision for retirement benefits, for which impact on profits is not ascertainable. Error in computation of margin of comparable companies 6. That on the facts and the circumstances of the case and in law, the AO/DRP erred in confirming the TPO's stand ... doubtful debts and bad debts written off as non-operating expenses for the purpose of margin computation of comparable companies as selected by TPO. Rejection of comparable companies 7 That on the facts and the circumstances of the case and in law, the AO/DRP ered by not including following companies

Skillnet Solutions India Private Limited, Mumbai, Maharashtra vs. Deputy Commissioner of Income Tax, Mumbai, Maharashtra

ITA 5078/MUM/2024[2021-22]Status: DisposedITAT Mumbai07 Nov 2024AY 2021-22

Bench: SHRI AMARJIT SINGH, ACCOUNTANT MEMBER SHRI RAHUL CHAUDHARY (Judicial Member)

For Appellant: Shri Sagar SawhneyFor Respondent: Shri Uodal Raj Singh

Section 143(3)Section 144BSection 144C(5)

circumstances of the case and in law, the Hon'ble DRP erred in not comparing three years weighted average OP/OC mark-up of comparable companies (post revenue adjustment in FY 2020-21) with the appellant's three years weighted average OP/OC mark-up. The above grounds of appeal are mutually

Parexel International Services India Pvt.Ltd, Chandigarh vs. ACIT, Circle-5(1), (Neac), Chandigarh

In the result, the appeal of the Assessee is partly allowed

ITA 129/CHANDI/2021[2016-17]Status: DisposedITAT Chandigarh28 Oct 2024AY 2016-17

Bench: SHRI. AAKASH DEEP JAIN (Vice President), SHRI. SHRI. KRINWANT SAHAY (Accountant Member)

For Appellant: Shri Dhanesh Bafna, CAFor Respondent: Shri Reuben Mathew Jacob, Addl. CIT, Sr. DR

Section 143(3)Section 234BSection 271(1)(C)

bench-marking analysis, consisting of uncontrolled transactions in the comparable set. 9. Pursuant to the direction of the ld. DRP, a fresh search of comparable companies were conducted by the TPO, upon which, a set of 20 companies engaged in IT enabled services were considered by the TPO, holding them