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INCOME TAX OFFICER & ANR. VS DIGICAPTIONS INDIA PVT. LTD. & ANR.
BANGALORE TRIBUNAL, Jan 07, 2021

1. IT(TP)A No.193/Bang/2016 is an appeal by the Revenue while IT(TP)A No.48/Bang/2016 is an appeal by the assessee. Both these appeals are directed against the final order...

Legislation Referred To : Section 143(3), 92CA
In Favour Of : Revenue(partly)

ASSISTANT COMMISSIONER OF INCOME TAX & ANR. VS ABB GLOBAL INDUSTRIES & SERVICES LTD. & ANR.
BANGALORE TRIBUNAL, Jan 04, 2021

Company having RPT beyond threshold limit of 15% cannot be selected as a comparable.

Subject : Transfer Pricing
Legislation Referred To : Section 143(3)
In Favour Of : Assessee and Revenue (partly)

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...

Subject : Transfer Pricing Adjustment
Legislation Referred To : Section 144C
In Favour Of : Assessee

DEPUTY COMMISSIONER OF INCOME TAX VS EXPEDITORS INTERNATIONAL (INDIA) PVT. LTD.
DELHI TRIBUNAL, Dec 17, 2020

Payments made by assessee as GAM charges cannot be treated as payment of salary to non-resident but were in nature of reimbursement of expenses and therefore assessee was...

Subject : Business Expenditure
Legislation Referred To : Section 40(a), 92CA(3)
In Favour Of : Assessee

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.

Subject : Transfer Pricing
Legislation Referred To : Section 115JB, 14A
In Favour Of : Assessee (partly)

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...

Subject : Transfer Pricing
Legislation Referred To : Section 260-A, 143(3)
In Favour Of : Assessee

EYGBS (INDIA) LLP (Earlier known as EYGBS (India) Pvt. Ltd.) VS DEPUTY COMMISSIONER OF INCOME TAX
BANGALORE TRIBUNAL, Nov 23, 2020

Once additional income on the basis of artificial/notional income is computed in the hands of assessee under the provisions of section 92(1) and offered for tax, it forms...

Subject : Exemption
Legislation Referred To : Section 10A, 92(1)
In Favour Of : Assessee

BERTELSMANN MARKETING SERVICES INDIA PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Nov 19, 2020

Before establishing that assessee is also a KPO, TPO cannot adopt another comparable KPO for comparability analysis.

Subject : Selection of comparables for information technology enables services
Legislation Referred To : Section 92CA(1)
In Favour Of : Assessee

TRANSCEND MT SERVICES PVT. LTD. VS DEPUTY COMMISSIONER OF INCOME TAX
DELHI TRIBUNAL, Nov 08, 2020

A comparable company having a turnover of Rs 260 crores cannot be compared with the assessee having only Rs. 11 crores turnover.

Subject : Selection of comparables for other segment
Legislation Referred To : Section 143(3), 144C(13), 234B
In Favour Of : Assessee (partly)

AGILENT TECHNOLOGIES INDIA PVT. LTD. VS ASSISTANT COMMISSIONER OF INCOME TAX & ANR.
HIGH COURT OF DELHI, Nov 06, 2020

1. The petition has been heard by way of video conferencing. 2. Present writ petition has been filed seeking directions to the respondents to grant a refund of Rs.5.19...

Legislation Referred To : Section 244A, 143(3)
In Favour Of : Assessee