Agilent Technologies (International) Pvt. Ltd. vs ITO

Authority: ITAT Tribunal/Court: Delhi Date: 2018-02-12 AY: 2010-11, 2011-12, 2012-13 Section: 10A, 115JB, 92B Acts: Income Tax Act 1961 Result: Partly Citation: 218Taxpundit249 Justices: AMIT SHUKLA JM & O. P. KANT AM Appeal No: I.T.As. No.1620/Del/2015, 477 & 6420/DEL/2016
Whether the Transfer Pricing Officer (TPO) erred in selecting certain companies as comparables for benchmarking the assessee's international transactions in IT and ITeS segments, leading to transfer pricing adjustments? --- Held Yes, the TPO's selection of comparables was flawed; specific companies (TCS E-Serve Ltd., Accentia Technology Pvt. Ltd., and E-Info Chip Bangalore Ltd.) were directed to be excluded as they were not functionally comparable or had extraordinary events affecting profitability.

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