Monday, 27 October 2014

Transfer pricing principles on right of TPO to collect info u/s 133(6

HSBC Electronic Data Processing India vs. ACIT (ITAT Hyderabad)

Transfer pricing principles on right of TPO to collect info u/s 133(6), exclusion of high profit comparables, adjustment for limited risk environment, exclusion of reimbursement costs for computing operation margins explained
(i) The TPO conducted search in the data bases for finding additional comparable by applying 25% employee cost filter. After examining the information obtained from the company u/s 133(6) of the Act the TPO treated it as comparable by observing that the company is engaged in IT enabled services and qualifies all the filters adopted […]

No comments:

Bombay High Court Clarifies Tax Exemption Eligibility for Venture Capital Funds

  In a significant ruling, the Bombay High Court has reaffirmed that a Venture Capital Fund (VCF) registered with SEBI is entitled to claim ...