COURT: | ITAT Delhi |
CORAM: | I. C. Sudhir (JM), R. S. Syal (AM) |
SECTION(S): | 92CA |
GENRE: | Transfer Pricing |
CATCH WORDS: | Related Party Transactions (RPTs), Transfer Pricing |
COUNSEL: | Pawan Kumar, Rohit Tiwari |
DATE: | November 28, 2014 (Date of pronouncement) |
DATE: | December 3, 2014 (Date of publication) |
AY: | 2004-05 |
FILE: | Click here to view full post with file download link |
CITATION: | |
Transfer Pricing: Comparables with more than 25% RPTs have to be excluded. There are no fetters on the assessee's right to claim that a comparable included by him should be excluded |
(i) The principal question about the exclusion of companies with more than 25% RPTs from the list of comparables on account of these becoming controlled transactions, has been fairly decided by various benches of the Tribunal. It has been held …
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