Dismissing the appeal of the assessee the Court held that , Inappropriate filters had been used by asssessee which would lead to an incorrect choice of comparables. DRP passed order excluding three companies from final set of comparables drawn by TPO.Tribunal partly allowed assessee’s appeal, however, upheld inclusion of Thirdware Solutions Limited and exclusion of CG Vak Soft-ware & Exports Ltd. and Quintegra Solutions Ltd. as comparables for benchmarking international transaction under software development services segment. High Court affirmed the order of the Tribunal . ( AY.2010-11)
Steria India Ltd v. DCIT (2018) 165 DTR 89 / 302 CTR 153 / 255 Taxman 110 (Delhi) (HC)
S. 92C : Transfer pricing – Arm’s length price -Comparability Parameters and Application of Filters- Inappropriate filters had been used by asssessee which would lead to an incorrect choice of comparables. DRP passed order excluding three companies from final set of comparables drawn by TPO-Tribunal partly allowed assessee’s appeal, however, upheld inclusion of Thirdware Solutions Limited and exclusion of CG Vak Soft-ware & Exports Ltd. and Quintegra Solutions Ltd. as comparables for benchmarking international transaction under software development services segment- Order of Tribunal is up held .