Held that while considering the comparable persistent Loss Filter the matter is remanded. Companies whose turnover in current year is more than Rs. 200 crores is to be excluded from list of comparables. Companies Lacking Segmental Information And Functionally Dissimilar with assessee cannot be taken as comparables. Interest on outstanding receivables matter is remanded. As regards rate of interest charged at Libor + 300 basis points considering credit period of 90 days. (AY. 2018-19)
Etisalat Software Solutions P. Ltd. v. Dy. CIT (2024) 111 ITR 475 (Bang)(Trib)
S. 92C : Transfer pricing-Arm’s length price-Avoidance of tax-International transaction-Selection of comparables-Persistent Loss Filter-Matter remanded-Turnover filter-Companies whose turnover in current year is more than Rs. 200 crores is to be excluded from list of comparables-Companies Lacking Segmental Information And Functionally Dissimilar with assessee cannot be taken as comparables-Interest on outstanding receivables-Matter remanded-Rate of interest charged at Libor + 300 basis points considering credit period of 90 days.[S.92B, 92CA]