Dismissing the appeal the Tribunal held that. while deciding assessee’s appeal for the assessment year 2002-03, the Tribunal had excluded KC Ltd. as a comparable since its turnover from information technology enabled services segment was less than Rs. 5 crores. Order of CIT(A) is affirmed. (AY.2003-04)
JCIT v. American Express (India) Pvt. Ltd. (2022) 93 ITR 45 (SN) (Delhi)(Trib.)
S. 92C : Transfer pricing-Arm’s length price–Transactional Net Margin Method-Selection of comparables-Tribunal for the earlier year directing exclusion of all companies having annual turnover less than Rs. 5 crores in Information Technology enabled services segment-Order of Transfer Pricing Officer including company having turnover below Rs. 5 Crores from Segment-Not justified. [S. 92CA]