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...the list of comparables and the same was reduced to 20. TPO also directed inclusion of Infosys Technologies Ltd. in the said list. The TPO in the final analysis has taken the comparables as under...:-““S. No. Name OP/TC (%)1 Satyam Computer Service Ltd. 30.072 L&T Infotech Ltd. 11.113 Infosys Technologies Ltd. 40.08...obvious reasons.5. The tribunal has observed that the assessee was not comparable with Infosys Technologies Ltd., as Infosys Technologies Ltd. was a large and bigger company in the ...
...submitted that the demand in question has arisen on account of not adjudicating the ground relating to comparability of Infosys Technologies Ltd., by this Tribunal. However, on the Miscellaneous Petition...moved by the assessee-company, this ground was recalled for adjudication and already posted for hearing for 5 April, 2017. He further submitted that in catena of decisions, Infosys Technologies Ltd., was...-company as Infosys Technologies Ltd., was held to be in-comparable in catena of decisions by co-ordinate benches of this Tribunal and also considering the fact that the appeal is already posted for hearing...
...the same assessment year, in Infosys Technologies Ltd. and claimed that the very same issue was elaborately considered in the said order and the appeal of the Revenue was dismissed.04...Income-tax (Appeals) in the case of Infosys Technologies Ltd., However, the assessee's counsel has placed on record copy of the order of the Tribunal in the case of Infosys Technologies whereby the Tribuna...of Infosys Technologies Ltd., has attained finality by the above said order. Further nothing has been brought on record by the Revenue to show that the said order of the Tribunal has been disturbed by...
..., the credit taken stands reversed by payment made on output service. In support, reliance was placed upon the decision of the its Coordinate Bench in Infosys Technologies Ltd. v. Commissioner of..., placed reliance upon the following observations of its Co-ordinate Bench in the case of Infosys Technologies Ltd. (supra), wherein it was held, as under...Counsel for the Revenue states that the Revenue has accepted the decision of the Tribunal in the case of Infosys Technologies Ltd., (supra). However, it is his contention that the aforesaid decision...
...Matter in the Appeal No. ST/126/2008-Mum filed by Infosys Technologies Ltd. by Final Order No. A/3241/2015-WZB/STB, dated 29-9-2015 and Misc. Order No. M/4702/2015-WZB/STB, dated 18-9-2015. Shri....[Infosys Technologies Ltd. v. Commissioner - 2016 (44) S.T.R. J158 (Tri.-Mum.)]...
...performing different functions or that the ratio of wages to sales was not comparable. He also considered the case of Infosys Technologies Ltd. as a comparable case. Thus, he considered 20 cases with...raised by the appellant. 3.2 It is further submitted that the main dispute in this case is regarding inclusion of the case of Infosys Technologies Ltd. This case has been included for the purpose of...transfer pricing adjustments by the TPO. However, the case is not comparable at all as the assessee is a pigmy compared to giant Infosys Technologies Ltd. The latters capital is ` 138 ITA No...
...CIT(A) found that while determining the arm's length price, the TPO considered five comparables which included Infosys Technologies Ltd. and Satyam Computer Services Ltd. He found that both the above...in assessee's own case, excluded Infosys Technologies Ltd. as well as Satyam Computer Services Ltd. from the list of comparables and found that the operating profit in respect of remaining three...cases; application of arbitrary filter of wage to sales ratio; ignoring that the assessee is a limited risk company; inclusion of Infosys Technologies Ltd.; and inclusion of Satyam Computers Services...
...in the appeal.
4. The only issue that arises in this appeal is as to whether Infosys Technologies Limited has been rightly excluded from the list of comparables for determining ALP?
...dated 13.10.2010 accepted it to be so before the TPO without any comment. However, it was challenged for the first time before the CIT(A). The assessee claimed that Infosys Technologies Ltd. was not a...valid comparable to the assessee as the assessee was a pigmy as compared to the giant Infosys Technologies Ltd.
6. The Tribunal while accepting the plea of the...
...the assessment year 2007-08, claiming the following substantial question of law:—"Whether the Hon'ble ITAT was correct in excluding Infosys Technologies Ltd. as a...in the appeal.4. The only issue that arises in this appeal is as to whether Infosys Technologies Limited has been rightly excluded from the list of comparables for determining ALP?5. No doubt, the...so before the TPO without any comment. However, it was challenged for the first time before the CIT(A). The assessee claimed that Infosys Technologies Ltd. was not a valid comparable to the assessee as...
...Short Term Capital Gain or Loss on such transactions. In relation to the other two scrips, namely, M/s. Infosys Technologies Ltd. and M/s. Larsen & Toubro Ltd., the CIT(A) affirmed the stand of the...that the transactions in the two scrips, namely, M/s. Infosys Technologies Ltd. and M/s. Larsen & Toubro Ltd. were on the same footing as the transaction in other ten scrips and, therefore, the CIT(A...pari materia to the period of holding reflected in the transactions of the two scrips, namely, M/s. Infosys Technologies Ltd. and M/s. Larsen & Toubro Ltd. Rather, in the case of some of the other scrips...
...Computer Services Ltd. 29.44 27.81 17 Infosys Technologies Ltd. 42.83 41.99 Arithmetical Mean 26.59 24.57 5. The TPO computed the addition to be made...stood excluded. Flextronics Ltd. L&T Infotech Ltd. Infosys Technologies Ltd. Satyam Computer Services Ltd. iGate Global Solutions Ltd. ITA Nos. 540 & 541, 616 & 617/B..., therefore, disapproved the use of this filter by the TPO. However, despite the same, Melstar Information Technologies Ltd., one of the comparables selected by the Assessee in its TP Study but which was...
...ANOTHER vs. M/s. INFOSYS TECHNOLOGIES LTD, in ITA No.422 of 2008 and connected matters, disposed off on 02.06.2014, whereby the said substantial questions of law were answered in favour of the...COMMISSIONER OF INCOME TAX AND ANOTHER vs. M/s. INFOSYS TECHNOLOGIES LTD. in ITA No.422 of 2008 and connected matters, disposed off on 02.06.2014, Following the said...TAX, CENTRAL-III vs. HCL TECHNOLOGIES LTD. reported in (2018) 93 Taxmann.com 33 (SC). Following the said judgment, the fourth substantial...
...worked as Technical Specialist with M/s HCL Technologies Ltd. from 01.04.2010 to 04.11.2010. In fact, according to the Ld. D.R., the assessee received a total salary of 20,20,995/- from HCL Technologies Ltd. Moreov...Ltd. as Project Manager. According to the Ld. D.R., the assessee has received a sum of 4,94,823/- from M/s Infosys Technologies...Ltd. On a query from the Bench, the Ld. D.R. submitted that both the companies have deducted tax at source at the time of making payment. However, the assessee admittedly disclosed only the income received from M/s Infosys ...
...% 8 Sasken Network Systems Ltd. 13.89% 9 Tata Elxsi Ltd. (Seg.) 22.78% 10 Visualsoft Technologies Ltd. (Seg.) 20.06% 11 Exensy...directed to re-compute the ALP. From I.T.A. No. 1761/Hyd/17 Virtusa (india) Pvt. Ltd., Hyd. the set of 17 comparales chosen by him; Exensys Software Solutions Ltd, Infosys Technologies ...material on record. In assessees own case for AY 2007-08 (supra), the coordinate bench of this tribunal with regard to Infosys Technologies Ltd., held as under: 2. Infosys ...
...said company and held to engaged in the business of software development.1. Whether Ld. CIT(A) in the facts and circumstances erred by directing AO to exclude Infosys Technologies Ltd. and...held to be engaged in the business of software development. The second issue raised by the Revenue is against exclusion of Infosys Technologies Ltd and L & T Infotech Ltd. as comparable only on the...made by the TPO and applied by the Assessing Officer and appealed against the order of Assessing Officer/TPO.6. The CIT(A) directed that FCS Software Ltd, Infosys Technologies Ltd. and...
...the facts and in the circumstances of the case and in law, the Ld. CIT(A) has erred in directing the A.O. to exclude Infosys Technologies Ltd. and Mindtree Ltd. from the list of comparable companies...filed by the Revenue is against exclusion of Infosys Technologies Ltd. and Mindtree Ltd. having very high turnover as against the turnover of assessee at Rs. 62.50 crores.6. The...concerns Infosys Technologies Ltd. and Mindtree Ltd. could not be taken as comparable having high turnover of Rs. 25,385 crores and Rs. 1509 crores, respectively. The learned Authorized Representative...
...% disclosed by the assessee. On appeal, learned CIT(A) found that while determining the arm's length price, the TPO considered five comparables which included Infosys Technologies Ltd. and Satyam Computer...assessee. The CIT(A), following the decision of ITAT in assessee's own case, excluded Infosys Technologies Ltd. as well as Satyam Computer Services Ltd. from the list of comparables and found that the...assessee is a limited risk company; inclusion of Infosys Technologies Ltd.; and inclusion of Satyam Computers Services Ltd. in spite of the fact that its data is not reliable as publicly known. On the...
...% disclosed by the assessee. On appeal, learned CIT(A) found that while determining the arm's length price, the TPO considered five comparables which included Infosys Technologies Ltd. and Satyam Computer...assessee. The CIT(A), following the decision of ITAT in assessee's own case, excluded Infosys Technologies Ltd. as well as Satyam Computer Services Ltd. from the list of comparables and found that the...assessee is a limited risk company; inclusion of Infosys Technologies Ltd.; and inclusion of Satyam Computers Services Ltd. in spite of the fact that its data is not reliable as publicly known. On the...
...% disclosed by the assessee. On appeal, learned CIT(A) found that while determining the arms length price, the TPO considered five comparables which included Infosys Technologies Ltd. and Satyam Computer...CIT(A), following the decision of ITAT in assessees own case, excluded Infosys Technologies Ltd. as well as Satyam Computer Services Ltd. from the list of comparables and found that the operating...Infosys Technologies Ltd.; and inclusion of Satyam Computers Services Ltd. in spite of the fact that its data is not reliable as publicly known. On the basis of these arguments, the DRP excluded the...
...working for M/s. Infosys Technologies Ltd. I.T.A. No.91/Mds/2010 During the assessment year 1999-2000 the assessee was granted ESOP by M/s. Infosys Technologies Ltd. The asse...filed his original return of income for the assessment year 1999-2000 on 2-6-1999. In the case of the assessees employer, M/s. Infosys Technologies Ltd., the TDS Officer had given a finding that on the...ESOP, TDS was liable to be made. Subsequently, on appeal the Hon'ble High Court of Karnataka in the case of Infosys Technologies Ltd. reported in 293 ITR 146 had held that no TDS was...