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