ADIENT INDIA PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
PUNE TRIBUNAL, May 31, 2021

Where transactions are of diverse nature, they would justify aggregation only if inter-related.

REPLICON SOFTWARE (INDIA) PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Mar 12, 2021

Functionally different companies cannot be selected as comparables

HUAWEI TELECOMMUNICATIONS (INDIA) PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Feb 24, 2021

It is beyond the jurisdiction of TPO to determine the benchmarking of technical services and project management services by applying the "benefit test" and "commercial...

BMC SOFTWARE INDIA PRIVATE LIMITED & ANR. VS DEPUTY COMMISSIONER OF INCOEM TAX & ANR.
PUNE TRIBUNAL, Jan 18, 2021

A company engaged in software products as well as Software Development services, income from both of which streams has been clubbed under segment of "Application Software"...

PRINCPAL COMMISSIONER OF INCOME TAX VS HEADSTRONG SERVICES INDIA PVT. LTD.
HIGH COURT OF DELHI, Dec 24, 2020

Once ITAT directed the assessing officer to decide the matter relating to transfer pricing de novo, it meant that a new hearing of the matter had to be conducted, as if the...

NTT DATA GLOBAL DELIVERY SERVICS PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Dec 17, 2020

Functionally different companies cannot be selected as comparables.

GLOBAL E-BUSINESS OPERATIONS PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Dec 04, 2020

A company engaged in providing KPO services and supported by their parent companies, having huge brand value cannot be selected as a comparable for a company engaged in...

LSI INDIA RESEARCH & DEVELOPMENT INDIA PRIVATE LIMITED VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Oct 16, 2020

Company having RPT in excess of 15% has to be excluded from the list of comparables.

INTERCONTINENTAL HOTELS GRUOP (INDIA) PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Oct 14, 2020

Company being a government enterprises is not comparable with a private business service provider because in case of government enterprises profit motive is not irrelevant...

DANISCO INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Oct 07, 2020

Assessing Officer/TPO cannot sit in judgment over the manner in which business have to be carried on by the businessman, domain of the TPO is limited to check whether...

JINDAL STAINELL LTD. & ANR. VS DEPUTY COMMISSIONER OF INCOME TAX & ANR.
DELHI TRIBUNAL, Sep 30, 2020

Merely because the transactions are for the export of the same goods over a period to the Associated Enterprises, they do not become interlinked. There has to be a binding...

TRX TECHNOLOGIES INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Sep 25, 2020

Functionally dissimilar companies cannot be selected as comparables.

GE INDIA BUSINESS SERVICES PRIVATE LIMITED VS ADDITIONAL COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Sep 16, 2020

When a particular comparable company is excluded from the comparability analysis in assessee's own case for earlier years, for whatever reasons, even if same was excluded...

KEC INTERNATIONAL LTD. AND ANR. VS DEPUTY COMMISSIONER OF INCOME TAX AND ANR.
BOMBAY TRIBUNAL, Sep 14, 2020

Where the advances were towards fulfilment of the assessee's obligation of being a JV partner as any financial incapacitation of JV would adversely affect the continuation...

M/S MIDLAND CREDIT MANAGEMENT INDIA PVT LTD AND ANR. VS ADDITIONAL COMMISSIONER OF INCOME TAX AND ANR.
DELHI TRIBUNAL, Sep 14, 2020

Functionally different entities having a high brand value cannot be selected as comparables.

ENTCO IT SERVICES PVT. LTD. (FORMERLY KNOWN AS INTERWOVEN SOFTWARE SERVICES INDIA PVT. LTD.) VS ASSISTANT COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Sep 08, 2020

A functionally different company having presence of brand and extraordinary event during the relevant year on account of acquisition cannot be selected as a comparable to a...

INCOME TAX OFFICER VS SABRE TRAVEL TECHNOLOGIES PVT. LTD.
BANGALORE TRIBUNAL, Sep 04, 2020

Functionally different companies cannot be selected as comparables

ASSISTANT COMMISSIONER OF INCOME TAX VS VOLVO AUTO (INDIA) PRIVATE LIMITED
DELHI TRIBUNAL, Aug 11, 2020

Transfer Pricing adjustment made on the basis on incorrect appreciation of facts is not sustainable.

MICROSOFT CORPORATION (INAI) PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Aug 07, 2020

When there is addition of civil work, such addition of civil work even on long lease is to be treated a building for providing depreciation.

NEW DELHI TELEVISION LTD. & ANR. VS ASSISTANT COMMISSIONER OF INCOME TAX & ANR.
DELHI TRIBUNAL, Jun 16, 2020

Incurring of liability and resultant deduction cannot be marred by mere reason of some difficulty in proper quantification of such liability at that stage, very point of...