Income Tax Appellate Tribunal – Pune
Entercoms Solutions Private … vs Acit Circle-1(2), Pune on 25 October, 2021 आयकर अपीलीय अधधकरण “सी” न्यायपीठ पुणे में ।
IN THE INCOME TAX APPELLATE TRIBUNAL “C” BENCH, PUNE
BEFORE SHRI R.S.SYAL, VP AND
SHRI PARTHA SARATHI CHAUDHURY, JM
आयकर अपील सं. / ITA No. 1826/PUN/2019
धनधाारण वषा / Assessment Year : 2015-16
Entercoms Solutions Private Limited
Unit No.301 & 302, NSG, IT Park,
ITI Road, Aundh,
Pune-411 007
PAN : AABCE3692G
…….अपीलाथी / Appellant
बनाम / V/s.
The Assistant Commissioner of Income Tax,
Circle-1(2), Pune.
……प्रत्यथी / Respondent
Assessee by : Shri Nikhil Pathak
Revenue by : Shri Shekhar L. Gajbhiye
सुनवाई की तारीख / Date of Hearing : 12.10.2021
घोषणा की तारीख / Date of Pronouncement : 25.10.2021
आदेश / ORDER
PER PARTHA SARATHI CHAUDHURY, JM:
This appeal preferred by the assessee emanates from the directions of
the Ld. Dispute Resolution Panel (DRP)-3, Mumbai dated 26.08.2019 passed
u/s.144C(5) of the Income Tax Act, 1961 for the assessment year 2015-16 as
per the following grounds of appeal:
“1. Based on the facts and circumstances of the case and in law, the
learned Assessing Officer („Ld. AO‟) and Hon‟ble Dispute Resolution
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Panel ( „Hon‟ble DRP) erred in making/upholding the transfer pricing
adjustment of INR 2,08,94,594/- to the taxable income of the
appellant.
2. Rejection of transfer pricing documentation (“TP study”)
maintained by the appellant and conducting fresh search on
incorrect basis
Based on the facts and circumstances of the case and in law, the
Hon‟ble DRP and Ld. Transfer Pricing Officer (Ld. TPO) erred in
rejecting the transfer pricing documentation maintained by the
Appellant in accordance with the provisions of the Act read with the
Income Tax Rules, 1962 (“Rules”) Consequently, the Hon‟ble DRP and
the Ld. TPO also erred in conducting fresh search for identification of
comparable companies.
In connection with rejection of TP study of Appellant the Hon‟ble
DRP/Ld. TPO erred in
Rejecting the search conducted ( for comparable companies) by
appellant without giving any cogent reasons;
Rejecting the TP study prepared by the Appellant merely on
the basis of difference in opinion with respect to certain filters
applied by the Appellant. In this regard,
– The Ld. TPO considered certain quantitative filters i.e.
i. Net Fixed Asset (NFA) more than 200% of sales and
ii. R & D cost of 3% of sales as inappropriate filters without
providing cogent reasons
– The Ld. TPO assumed that quantitative filter of ITes service
income> 75% can be applied and incorrectly stated that
Appellant‟s quantitative filter of service income> 75% is
incorrect. Moreover, even after rejecting the Appellant‟s TP
study, the Ld. TPO himself applied the same filter of service
income> 75% while conducting fresh search.
3. Inappropriate fresh search conducted by the Ld. TPO for
identification of comparable companies ( without prejudice to
Ground No.2)
Based on the facts and circumstances of the case and in law, the
Hon‟ble DRP erred in upholding the incorrect and inappropriate
process followed by the Ld. TPO for conducting fresh search for
identification of comparable companies considered in the final TP
order.
In doing so, the Hon‟ble DRP/Ld. TPO erred in
Not making available to the Appellant the relevant information
(including but not limited to the relevant details claimed to be
collected by the Ld. TPO from the companies under section
133(6) for conducting comparability analysis) pertaining to such
fresh search conducted by the Ld. TPO, so as to enable the
Appellant to peruse such relevant information and have a
realistic opportunity of being heard.
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Application of certain quantitative filters in the fresh search
without providing cogent rationale for the same.
Rejecting Informed Technologies India Ltd. on the basis of it
failing the quantitative filter of service income> 75% of total
income, wherein the service income of Informed Technologies
India Ltd. is more than 75%.
Rejecting Datamatics Global Services Ltd. and Cosmic Global
Ltd. on the basis of it is failing export filter whereas these
companies have exports more than 75%.
Rejecting Allsec Technologies Ltd. on the basis of it being
persistent loss making company even though it is not persistent
loss making company.
Rejecting Microland Limited (Seg.) on the basis of insufficient
ITes segment even though adequate ITes segment data is
available from Annual Report.
Rejecting R Systems Intl Ltd. merely on the basis of company
having different financial year despite this company being
functionally comparable.
Selection of functionally dissimilar companies as comparable
viz. Infosys BPO Ltd., Tech Mahindra BSPL, AGS Health Private
Limited and E-Care India Pvt. Ltd. without conducting proper
quantitative analysis and without rebutting the Appellant‟s
submission explaining functional dissimilarity of these
companies.
Considering Cross Domain Solutions Pvt. Ltd., Excel Infoways
Limited ( Segment), SPI Technologies India Pvt. Ltd. and ICRA
Techno Analytics Ltd. in final set of comparable companies in
the TP order even though these companies are not appearing in
the search (population) undertaken by the Ld. TPO for fresh
search of comparables. Thus, the Hon‟ble DRP/Ld. TPO erred
by adopting cherry picking approach to consider these high
profit making companies as comparable companies.
Not selecting Digicall Global Pvt. Ltd. and Sutherland Global
Services Pvt. Ltd. as comparable companies despite the
Appellant providing detailed submissions explaining functional
similarity of these companies with some of the other companies
selected by the Ld. TPO as comparable during the fresh search.
4. Risk Adjustment not granted
The Hon‟ble DRP erred and the Ld. TPO erred in not granting any
risk adjustments for differences in risk borne by the comparable
companies vis-à-vis the Appellant.
5. Working capital adjustment not granted
The Hon‟ble DRP erred and the Ld. TPO erred in not granting
working capital adjustment to the Appellant which could have
nullified the impact of different level of working capital ( deployed
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by the Appellant and comparable companies) on the benchmarking
analysis and in disregarding the fact that working capital
adjustment takes into account the difference between credit period
of the Appellant and the comparable companies.
6. Notional Interest imputed incorrectly
The Hon‟ble DRP erred in upholding action of the Ld. TPO of
imputing notional interest by:
Disregarding the fact that working capital adjustment (as
requested by the Appellant) takes into account the
differences if any, between credit period of the Appellant
and independent comparable companies.
Re-characterizing outstanding receivables as an unsecured
loan advanced by the Appellant to its AE.
Without prejudice basis the Appellant prays that the
Hon‟ble DRP and Ld. TPO erred in computing notional
interest for the full period of delay and not restricting it to
the period of excess of reasonable credit period/average
credit period of comparables.”
2. Referring to grounds of appeal, the Ld. Counsel for the assessee
submitted that the dispute in this case is with regard to comparables only. In
this regard, at the very outset, he submitted that the assessee is not pressing
Ground No.6. After recording the submissions of the Ld. Counsel, Ground
No.6 is dismissed as not pressed.
3. Thereafter, the Ld. Counsel for the assessee brought to our notice the
final list of comparable companies selected by the Transfer Pricing Officer
(TPO) at Page 33 of his order. The TPO has considered 11 companies in the
final list of comparables in the ITes segment in respect of the assessee. That
out of these 11 companies, the assessee is disputing four companies as
comparables which are (A) SPI Technologies India Pvt. Ltd., (B) AGS Health
Pvt. Ltd., (C) Infosys BPO Ltd. and (D) Tech Mahindra BSPL
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4. Giving a brief background to the case, the Ld. Counsel for the assessee
submitted that the assessee is doing business of ITes segment wherein major
work is of analytical support and functions with software services as only
incidental to and not independent of such analytical functions. It was also
clarified by the Ld. Counsel that Master Technical Service Agreement dated
8th December, 2004 between ECMi LLC and ECMi Software Private Limited
provides for software services, that however, from 2013 onwards, there has
been a drastic amendment as to the Master Services Agreement and for the
year under consideration i.e. financial year 2014-15 relevant to assessment
year 2015-16, the services of the assessee are to provide after-market
analytical services and only related software support. Meaning thereby, what
the assessee was doing in 2004, was essentially providing software services
which got amended from April, 2013 for the financial year 2014-15 and after
that the assessee is providing analytical services and only related software
and technical support services. These agreements are annexed at Pages 1500
and 1520 in the paper book filed before us.
4.1 The Ld. Counsel also brought to our notice the functional analysis of
the assessee company which is annexed in the paper book at Pages 29
onwards wherein at Para 7.2, it is specifically mentioned that Entercoms
Group focuses exclusively on aftermarket/post-sales service chain operations.
There is detailed discussion of the functions performed by Entercoms US and
Entercoms India. That taking us through these detailed functional analysis,
the Ld. Counsel demonstrated what essentially Entercoms India does is to
provide aftermarket analytical services through its COPS teams. The
analytical services are performed using software developed and owned by
Entercoms US. This discussion finds place from Para‟s 7.14 onwards in the
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functional analysis statement. Thereafter, the Ld. Counsel for the assessee
submitted that inclusion of following comparables companies are disputed in
the ITes segment of the assessee:
(A) SPI Technologies India Pvt. Ltd.:-
5. SPI Technologies India Pvt. Ltd. offers a range of voice and non-voice
business process outsourcing solutions; and content editorial and production
service that consist of content transformation services such as content
enrichment, content conversion, content structuring and content delivery
across various data and delivery formats. The assessee objected that this
company is not comparable to the assessee on account of being functionally
dissimilar. The TPO, however held that SPI Technologies India Pvt. Ltd.
clearly falls under the definition of ITes and hence, comparable to that of the
assessee company.
6. The Ld. DRP has given their directions on this issue vide Para 7.2
onwards. Thereafter, at Para 7.2.1, the Ld. DRP had upheld the observation of
the TPO and held that all the objections of the assessee were dealt with and
discussed and the findings of the TPO was upheld.
7. The Ld. Counsel for the assessee at the time of hearing submitted that
the main reason for objecting to the comparable was not because they are
doing software services but for essential other factors which ultimately makes
this selected company as non-comparable with that the assessee. That SPI
Technologies India Pvt. Ltd. in the relevant assessment year, there has been
an amalgamation of this company and due to the extraordinary events this
company is to be rejected. Demonstrating these facts, the Ld. Counsel for the
assessee took us through the Annual Report of SPI Technologies India Pvt.
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Ltd. at Page 1331 wherein, there is a disclosure by the Board of Directors that
amalgamation has taken place between Laserwords Private Limited, a wholly
owned subsidiary of SPi Technologies India Private Limited (the
Amalgamating Company) with SPI Technologies India Private Limited ( the
Amalgamated Company) pursuant to Section 391 to 394 of the Companies
Act, 1956 with appointed date as April 1, 2014 i.e. financial year 2014-15
relevant to assessment year 2015-16. This scheme was sanctioned by the
Hon‟ble High Court of Judicature at Madras vide order dated 22.08.2014
which was filed with the Registrar of Companies, Chennai on 4th October,
2014 being the effective date. This fact of amalgamation taking place in
respect of SPI Technologies India Pvt. Ltd. during relevant assessment year
was also brought to the notice of the Ld. DRP at the time of objections raised
before it by the assessee and the relevant submissions before the Ld. DRP
have been annexed before us in the paper book 1 page 516 onwards.
However, the Ld. DRP has not given any findings on this aspect.
8. We find the Hon‟ble Jurisdictional High Court in the case of Pr.
Commissioner of Income Tax Vs. PTC Software (I) (P) Ltd. (2019) 101
taxmann.com 117 ( Bombay) has held that in case the assessee rendering
ITES services to AE, a company in whose case extraordinary event of
amalgamation took place during relevant year, could not be accepted as
comparable and was decided in favour of the assessee. Similarly in the case of
Pr. Commissioner of Income Tax Vs. J.P Morgan India (P) Ltd. (2019) 102
taxmann.com 335 (Bombay) , the Hon‟ble Jurisdictional High Court on the
same issue has held as follows:
“(iv) Mr. Percy Pardiwalla, learned senior counsel appearing on behalf of
the respondent invited our attention to the final decision of
this Court in Pr. CIT v. Aptara Technology (P.) Ltd. [2018] 92
taxmann.com 240 and Pr. CIT v. PTC Software (I) (P.) Ltd. [2019] 101
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taxmann.com 117 (Bom.). In both the above decisions this Court has
taken a view that merger/amalgamation is an extra ordinary event and
would have an impact /effect on the financial results of the company.
Thus, in both the aforesaid decisions, this Court upheld the view of the
Tribunal that where merger/amalgamation have taken place and it is
not a normal event then such a company would cease to be comparable.
This of course is subject to the Revenue being able to show
that amalgamation/merger did not have any effect of the profitability of
the company. This has not been shown by the Revenue either to the
Tribunal or before us. Therefore, this issue stands covered by the
decision of this Court in Aptara Technology (P.) Ltd.’s case (supra)
and PTC Software (I) (P.) Ltd.’s case (supra) in favour of the respondent.
This more particularly in view of the absence of the Revenue even
attempting to show that the merger and amalgamation that took place
in the case of comparable M/s. Keynote Corporate Securities Limited was
such that it would not have any impact on its profitability. It is true that
in case of PTC Software (I) (P.) Ltd. case (supra) this question has been
admitted, however, the admission was on the facts and circumstances of
that case. In any case the issue now stands concluded by final orders of
this Court in case of Aptara Technology (P.) Ltd. (supra) and PTC
Software (I) (P.) Ltd.’s case (supra) and it is being followed.
(V) In view of the above, as the proposed question is covered by the
decision of this Court, no substantial question of law arises. Thus, not
entertained.”
9. That even the Pune Bench of the Tribunal in the case of Brintons
Carpets Asia (P) Ltd. Vs. Deputy Commissioner of Income Tax, ITA
No.1312 & 1349/PN/2015 dated 29th March, 2019 observed that the
assessee before the Tribunal had first claimed that Accentia Technologies Ltd.
cannot be selected in the final list of comparables as during the year under
consideration, there was an extraordinary event of amalgamation. Thereafter,
the Tribunal has analyzed how and what extraordinary event took place in
that case and in such scenario, the company cannot be considered as
comparable one and the relevant extracts in this regard are as follows:
“13. ………………….The learned Authorized Representative for the
assessee has pointed out that though the CIT (A) says that there is no
such amalgamation but his finding is totally incorrect. In this regard,
reliance was placed on the ratio laid down by Pune Bench of Tribunal in
Dover India (P.) Ltd. v. Dy. CIT [2017] 88 taxmann.com 115 (Pune – Trib.),
wherein for assessment year 2010-11 itself, the said concern Accentia
Technologies Ltd. was excluded being high end KPO service provider.
Further, the Tribunal in BNY Mellon International Operations (India) (P.)
Ltd. (supra) have noted the extraordinary event of acquisition and also
amalgamation of another concern and held that the said concern could
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not be selected as comparable. The relevant findings of Tribunal are in
paras 12 and 13, which read as under:–
’12. The next concern against which the assessee has raised
objections is Accentia Technologies Ltd. on the ground of
extraordinary events during the year under consideration. The
said concern had acquired IQ group of companies in the United
Kingdom and there was amalgamation of Asscent Infoserve Pvt.
Ltd. with the said concern and because of these extraordinary
events, the margins of said companies should not be included in
the final set of comparables. The Pune Bench of Tribunal in Aptara
Technologies Pvt. Ltd. v. ACIT (2016) 72 taxmann.com 352 (Pune –
Trib) and Cummins Turbo Technologies Ltd. v. DCIT (2017) 79
taxmann.com 260 (Pune – Trib) has held that the said concern
cannot be accepted as comparable. The Tribunal in Aptara
Technologies Pvt. Ltd. v. ACIT (supra) held as under:–
“14. We find that the Tribunal in assessee’s own case in
assessment year 2008-09 in ITA No.2235/PN/2012, order dated
02.02.2015 had held that the said concern could not be
considered as comparable because of certain extraordinary
events. The said ratio was also applied in assessee’s own case
while benchmarking the international transaction of assessee
with its associate enterprises in assessment year 2009-10 in ITA
No.267/PN/2014, order dated 29.04.2015. The Tribunal vide
order dated 02.02.2015 had held that the concern Accentia
Technologies Ltd. could not be included in the final set of
comparables holding as under:–
“13. Next, assessee had contended that Accentia Technologies
Ltd. has been wrongly included by the TPO as a comparable
concern. As per the assessee, the said concern was engaged in
functionally different activities. It was pointed out that the said
concern is engaged in providing medical transaction, billing and
coding services, application development & customization
(segmental data not available). Moreover, it was contended that
the sales/turnover of the said concern was more than Rs. 50
crores for the year under consideration which did not meet with
turnover filter applied by the assessee. On this point, it was
pointed out that the assessee had selected sales/turnover filter of
1-50 crores i.e. any concerns having a turnover exceeding Rs. 50
crores were excluded. Thirdly, it was pointed out that the
activities of the said concern were not comparable to the activities
of the assessee.
14. The TPO has noted the aforesaid objections of the assessee in
para 18.1 of his order and has rejected the same by merely
noticing that 75% of the revenue/income of the said concern is
from ITES and therefore it is to be considered as a comparable.
Before us, the Ld. Representative for the assessee has reiterated
the submissions put-forth before the TPO in order to justify
exclusion of the said concern from the list of comparables. In
particularly, it has been pointed out that for the very same
assessment year, the Bangalore Bench of the Tribunal in the case
of Symphony Marketing Solutions India Pvt. Ltd. v. ITO, (2013) 38
taxmann.com 55 (Bang.) has excluded the said concern from the
list of comparables in a similar situation following the decision of
the Hyderabad Bench of the Tribunal in the case of Capital IQ
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Information Systems (India) Private Limited v. DCIT, (2013) 32
taxmann.com 21 (Hyd.).
15. We have considered the submissions of the Ld. Representative
for the assessee and also the stand of the Revenue as emerging
from the order of the TPO. In our view, the ratio laid down by the
Hyderabad Bench of the Tribunal in the case of Capital IQ
Information Systems (India) Private Limited (supra) and by the
Bangalore Bench of the Tribunal in the case of Symphony
Marketing Solutions India Pvt. Ltd. (supra) is squarely applicable
to the present case also. The aforesaid Benches of the Tribunal
found that during the year under consideration there were
extraordinary events that took place in the said concern which
warranted exclusion of this company as a comparable. We
therefore hold that the said concern cannot be considered as a
comparable.”
15. Further, similar proposition has been laid down by different
Benches of Tribunal while deciding the appeals relating to
assessment year 2010-11 and it has been held that because of
extraordinary events during the year, the concern Accentia
Technologies Ltd. was not comparable to the entities engaged in
ITES. Following the same parity of reasoning, we hold that
Accentia Technologies Ltd. is to be excluded from the final set of
comparables.”
13. Following the same parity of reasoning as in Aptara
Technologies Pvt. Ltd. v. ACIT (supra) and Cummins Turbo
Technologies Ltd. v. DCIT (supra), we hold that Accentia
Technologies Ltd. cannot be compared as comparable because of
extraordinary events of acquisition and amalgamation during the
year. Accordingly, we direct the Assessing Officer/TPO to exclude
Accential Technologies Ltd. from final list of comparables.”
10. We, place reliance on the afore-stated judicial precedents where there is
an emerging consistent view in this regard that if an extraordinary event has
taken place by way of amalgamation that company cannot be considered as a
comparable one and following the same parity of reasoning, we direct the
Assessing Officer/TPO to exclude SPI Technologies India Pvt. Ltd. from
the final set of comparables while computing international transactions
in respect of the assesse in ITes segment.
(B) AGS Health Pvt. Ltd.:-
11. AGS Health Pvt. Ltd. is a revenue cycle management company which
provides medical billing and medical transcription services to its customers.
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The assessee contended that this company is not comparable for two reasons
viz. (i) functional comparability and (ii) insufficient information in public.
12. The Ld. Counsel for the assessee on this issue brought to our notice at
Page 6 of the TPO‟s order wherein the TPO himself acknowledged that the
companies which have transactions with related parties are greater than 25%
are eliminated and it is an appropriate filter. Thereafter, the Ld. Counsel for
the assessee took us through the notes on related party explanatory and
therein in the Column „transaction with related parties‟ in respect of AGH
Health Pvt. Ltd., sale of service as on 31.03.2015 for the assessment year
2015-16, it was at Rs.133,26,47,750/-.
13. That it was also submitted before the Ld. DRP vide submissions dated
25th February, 2019 by the assessee that as per Annual Report of AGS Health
Pvt. Ltd., it had earned 100% of its revenue from related party during
financial year 2014-15. That it is very clear thus, AGS Health Private Limited
is not clearing the filter of „companies that have transactions with related
parties are greater than 25% are eliminated‟ which was applied by the
assessee and upheld by the Ld. TPO. In view of this, assessee prayed that
AGS Health Private Limited should be rejected as comparable company as the
same is not clearing the RPT filter.
14. The Ld. DR conceded to the fact of TPO‟s observation at para 7.2 of his
order wherein the TPO has accepted assessee‟s contention that companies
which have transactions with related parties are greater than 25%, they are
eliminated and it has been held by the TPO as an appropriate filter. That on
further examination of the Annual Report of AGH Health Private Limited, we
find that it is far beyond 25% that AGS Health Private Limited has earned its
revenue from related parties transactions and when the assessee in its TP
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study report has eliminated this company and it has been held as an
appropriate filter by the TPO then there remains no basis for revenue again to
include this company in the final set of comparables with that of the
assessee. Accordingly, we direct the Assessing Officer/TPO to exclude
AGS Health private Limited from the final set of comparables while
computing international transactions in respect of the assesse in ITes
segment.
(C) Infosys BPO Ltd.:-
15. Infosys BPO Ltd. offers business process outsourcing solutions to
several clients and its service offerings span across multiple industry
segments. The assessee submitted that this company is not comparable on
account of two reasons viz. (i) functionally different and (ii) High turnover. The
TPO was of the view that this company though engaged in different verticals
across the industry does not change the nature of functions carried out. The
functions are basically in the nature of business process out sourcing which
can be classified as ITes, thus, held to be functionally comparable with that of
the assessee company.
16. The Ld. DRP vide common order had upheld the findings of the TPO
without any discussion as regards the objections raised by the assessee
before it. The Ld. DRP had summarily disposed of the objections of the
assessee upholding the findings of the TPO.
17. In this regard, the Ld. Counsel for the assessee placed strong reliance
on the decision of the Hon‟ble Bombay High Court in the case of CIT Vs.
Pentair Water India Pvt. Ltd., 381 ITR 216 wherein the Hon‟ble High Court
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observed that the findings of the Tribunal given in respect of HCL Comnet
Systems and Services Ltd. as follows:
“We find force in the submission of the ld. AR that this company cannot
be a comparable as the turnover of this company is 260.18 crores while
in the case of the Assessee, the turnover is around Rs.11 crores only.
While making the selection of comparables, the turnover filter, in our
opinion, has to be the basis for selection. A company having turnover of
Rs.11 crores cannot be compared with a company which is having
turnover of Rs.260 crores which is more than 23 times the turnover of the
Assessee. This company cannot be regarded to be in equal size to the
Asseessee. We, accordingly, direct the AO to exclude this company out of
the comparables.”
Thereafter, the Hon‟ble High Court held the said findings of the
Tribunal are on the basis of appreciation of evidences on record, hence, no
infirmity found. In this decision, it was observed by the Hon‟ble Jurisdictional
High Court that while making the selection of comparables, the turnover
filter, has to be the basis for selection. A company having turnover of Rs.11
crores cannot be compared with a company which is having turnover of
Rs.260 crores which is more than 23 times.
18. Reverting to the facts of the present case, we find that the total
turnover of Entercoms Solutions Private Limited is Rs.38.4 Crore as on
31.03.2015 relevant to assessment year 2015-16 whereas the turnover as per
profit and loss account of Infosys BPO Ltd. is Rs.2510 Crores which is almost
80 times more than the assessee. Following the decision of the Hon‟ble
Jurisdictional High Court (supra.) on the basis of turnover filter, we direct
the Assessing Officer/TPO to exclude Infosys BPO Limited from the final
set of comparables while computing international transactions in
respect of the assesse in ITes segment.
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19. With regard to the comparable Tech Mahindra BSPL, the Ld. Counsel
submitted that he is not pressing this part of the ground. After recording the
submissions of the Ld. Counsel, this part of the ground is dismissed as not
pressed.
20. In the result, appeal of the assessee is partly allowed.
Order pronounced on 25th day of October, 2021.
Sd/- Sd/-
R.S.SYAL PARTHA SARATHI CHAUDHURY
VICE PRESIDENT JUDICIAL MEMBER
पुणे / Pune; ददनांक / Dated : 25th October, 2021.
SB
आदेश की प्रधतधलधप अग्रेधषत / Copy of the Order forwarded to :
1. अपीलाथी / The Appellant.
2. प्रत्यथी / The Respondent.
3. The CIT(Appeals)-13, Pune.
4. The Pr. CIT-5, Pune.
5. धवभागीय प्रधतधनधध, आयकर अपीलीय अधधकरण, “सी” बेंच,
पुणे / DR, ITAT, “C” Bench, Pune.
6. गार्ा फ़ाइल / Guard File.
आदेशानुसार / BY ORDER,
// True Copy //
धनजी सधचव / Private Secretary
आयकर अपीलीय अधधकरण, पुणे / ITAT, Pune. 15
ITA No. 1826/PUN/2019
A.Y.2015-16
Date
1 Draft dictated on 12.10.2021 Sr.PS/PS
2 Draft placed before author 25.10.2021 Sr.PS/PS
3 Draft proposed and placed JM/AM
before the second Member
4 Draft discussed/approved by AM/JM
second Member
5 Approved draft comes to the Sr.PS/PS
Sr. PS/PS
6 Kept for pronouncement on Sr.PS/PS
7 Date of uploading of order Sr.PS/PS
8 File sent to Bench Clerk Sr.PS/PS
9 Date on which the file goes to
the Head Clerk
10 Date on which file goes to the
A.R
11 Date of dispatch of order
Comments