THE PR. COMMISSIONER OF INCOME TAX GURGAON vs. M/S EQUANT SOLUTIONS INDIA PVT LTD

Appeals stand disposed of in the above terms

Bench: MR. JUSTICE AJAY TEWARI,MRS. JUSTICE ALKA SARIN

Section 19 CA(3) of the Income Tax Act, 1961 (for short the 'Act') on 9th January, 2014 accepting TNMM as the most appropriate method, however, the Transfer Pricing Officer chose certain comparables for IT services and ITES services with a mean “OP/TC” of 25.17 of IT services and 30.45% for IT enabled services and proposed transfer pricing adjustments

M/S PUNJAB INSTITUTE OF MEDICAL SCIENCES, GARHA ROAD , JALANDHAR vs. COMMISSIONER OF INCOME TAX JALANDHAR AND ANR

Bench: MR. JUSTICE SANJEEV PRAKASH SHARMA,MR. JUSTICE SANJAY VASHISTH

Section 12A of the Act vide order dated 20.05.1994 with effect from 06.04.1994. The main objects of the society were: (a) to establish and carry on the administration and management of Punjab Institute of Medical Sciences, Jalandhar; and (b) to set up, establish, promote, manage or associate with any other Institution or Centre in the State of Punjab devoted