Infosys

Turnover filter & comparisons – Important principles explained

CLR Editorial Notes: The Tribunal had to consider the following important transfer pricing issues: (i) whether a one-time and extraordinary item of expenditure (ESOP cost) debited to the assessee™s P&L A/c has to be excluded while comparing the margins, (ii) whether for the purpose of comparison of margins, the consolidated results of comparables having profit… Read More

Tags: American ExpressComparablesInfosysOECDPuneTPOtransfer pricing

Turnover filter must be applied to exclude giant companies from comparison

CLR Editorial Notes: The assessee-company is engaged in the business of software development services to its customers. The assessee also provides services to the Associated Enterprise AE namely Patni Telecom, U.S. and Patni Telecom, U.K. The assessee filed return of income for the assessment year 2008-2009 admitting total income of Rs.87,850/- under the normal provisions of the Income Tax Act, 1961… Read More

Tags: CapgeminiIncome Tax Act 1961Infosystransfer pricingWipro

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