Tribunal held that the Companies having different functional profile and Companies for which segmental details not available are to be excluded. Profit margin at entity level could not be taken . Working capital adjustment to be given effect . Communication charges should be excluded both from export turnover and total turnover for the purpose of S.10A of the Act . ( AY.2007-08, 2010-11)
Gxs India Technology Centre Pvt. Ltd. v. ITO (2021) 85 ITR 24 (SN)(Bang) (Trib)
S. 92C : Transfer pricing – Arm’s length price – Net Margin Method —Companies having different functional profile — Companies for which segmental details not available are to be excluded – Profit margin at entity level could not be taken -Working capital adjustment to be given effect -Communication charges should be excluded both from export turnover and total turnover [ S.10A ]