THE PR. COMMISSIONER OF INCOME TAX GURGAON vs. M/S EQUANT SOLUTIONS INDIA PVT LTD
Appeals stand disposed of in the above terms
ITA/419/2016HC Punjab & Haryana30 Oct 2019
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