2016-TII-INSTANT-ALL-306
23 March 2016   

CASE LAW

2016-TII-152-ITAT-BANG-TP

TELELOGIC INDIA PVT LTD Vs ACIT: BANGALORE ITAT (Dated: March 16, 2016)

Income Tax - Section 92CA(3).

Keywords - accumulated losses - AE - ALP - proposal for merger - TNMM - TP adjustment.

Whether proposal for merger, accumulated losses being more than 50% of net worth and increase in turnover is not a relevant factor for excluding a company as a comparable - YES: ITAT

Whether the companies having related party transactions of not exceeding 15% can be taken as a comparable - YES: ITAT

Appeals partly allowed

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