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TPO to provide info. collected u/s 133(6) I.T.Act to assessee in TP case. ITAT

Assessee-Co. provided advisory & support services to its AEs. It had international transact'ns with associated enterprises. In TP report assessee benchmarked margin at cost plus 12.33% by taking 14 comparable. However, TPO at 30.49% on basis of 19 comparables. TPO made an upward adjustm't to arm's length. DRP set aside objections raised by assessee. On appeal ITAT directed AO/TPO to provide the information collected TPO u/s 133(6) to assessee

Facts in Brief:

1. The assessee-company was engaged in the business of providing advisory and support services to its AEs. It had entered into international transactions with the associated enterprises.

2. In transfer pricing report the assessee arrived at benchmarking margin at cost plus 12.33 per cent by taking fourteen comparables. However, the TPO arrived at benchmarking margin of 30.49 per cent on the basis of 19 comparables taken by him.

3. Accordingly, the TPO made an upward adjustment to the arm's length in relation to the international transactions entered into by the assessee-company with its associated enterprises.

4. The DRP set aside objections raised by the assessee.

On appeal, ITAT held as under:

5. The matter is resoted back to the file of Assessing Officer/TPO for recomputing benchmarking margin and to determine arm's length price of assessee's international transaction of provisions of business support services.

RELEVANT PARAS OF THE JUDGEMENT ARE AS UNDER:

6. In view of order of the Tribunal in the case of Hyundai Motors India Engg. (P.) Ltd. v. ITO [2015] 152 ITD 112/[2014] 44 taxmann.com 34 (Hyd. - Trib.) it is found that this company is not functionally comparble and it had a different employee skill set and also performed R & D services and also owned intangibles. Accordingly, the TPO is directed to exclude Genesys International Corporation Ltd. from the list of comparables. [Paras 12 and 13]

7. With regard to e-Clerx Services (P.) Ltd., it was contended by assessee that this company is engaged in providing data analytics and data process solution to the largest brands in the world. They are recognized experts in financial services, retails and manufacturing. The assessee also brought on record the following decision of ITAT, wherein this company was excluded from the list of comparables:

(i) Symphony Marketing Solutions India (P.) Ltd. v. ITO [2013] 38 taxmann.com 55 (Bang.)

(ii) Hyundai Motors India Engg. (P.) Ltd.'s case (supra)

(iii) Maersk Global Centres (India) (P.) Ltd. v. Asstt. CIT [2014] 147 ITD 83/43 taxmann.com 100 (Mum. - Trib.) (SB) and

(iv) Lionbridge Technologies Ltd. v. ITO [2014] 151 ITD 553/48 taxmann.com 46 (Mum. - Trib.)

Considering the judicial pronouncements as cited above, the Assessing Officer is directed to exclude e-Clerx Services (P.) Ltd. from the list of comparables.

8. The assessee also contended for exclusion of Accentia Technologies Ltd. It was found that the TPO after collecting information under section 133(6) assessee had included it as a comparable. The plea of the assessee is that it has software development activity also, therefore, non-comparable with the functional activity of the assessee. In the interest of justice, this matter is remitted back to the file of the TPO for examining afresh. The information collected by him under section 133(5) is to be supplied to assessee. It is directed accordingly. [Para 16]

9. The assessee has also contended for exclusion of Mold Tek Technologies Ltd. on the plea that it has extra ordinary events happened during the year, i.e., amalgamation with Tech Men Tools (P.) Ltd.

10. It was found that the ITAT Special Bench in the case of Maersk Global Centres (India) (P.) Ltd., (supra) has directed for exclusion of Mold Tek Technologies Ltd. On the plea that the financial year 2007-08 relevant to assessment year 2008-09 was a unique year for Mold Tek Technologies Ltd., as the scheme of arrangement involving amalgamation between Tekmen Tool (P.) Ltd. And Mold Tek Technologies Ltd. and de-merger between Mold Tek Technologies Ltd. Simultaneously was sanctioned by the AP High Court by 15-7-2008 with the appointed date for amalgamation and de-merger being 1-9-2007 and 1-4-2007, respectively. In view of the above, respectfully following the decision of Special Bench, the TPO is directed to exclude Mold Tek Technologies Ltd. from the list of comparables.

11. The assessee has also contended for exclusion of Infosys BPO Ltd. on the plea that it is a giant company having turnover of Rs. 825.08 crore.

12. It was found that Infosys BPO Ltd., being a subsidiary of Infosys, has an element of brand value associated with it. This is also clear from the present of brand related expenses incurred by this company. Presence of a brand commands premium price and the customers would be willing to pay, for the services/products of the company. Infosys BPO is an established player who is not only a market leader but also a company employing sheer breadth in terms of economies of scale and diversity and geographical dispersion of customers. The presence of the aforesaid factors will take this company out of the list of comparables. Therefore, the contention of the assessee that this company cannot be regarded as a comparable is accepted.

13. The assessee has also contended for exclusion of Wipro Ltd. on the plea that it is a giant company having turnover of Rs. 11,57.20 crores and it owns tangibles. Reliance was placed on (i) Symphony Marketing Solutions India (P.) Ltd.'s case (supra) (ii) Hyundai Motors India Engg. (P.) Ltd.'s case (supra) and (iii) Stream International Services (P.) Ltd. v. Asstt. CIT [2015] 53 taxmann.com 19 (Mum. - Trib.)

14. In view of the judicial pronouncements, the contention of the assessee that Wipro Ltd. cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude this company from the list of comparables.

15. The assessee has also contended for exclusion of Maple e-Solution Ltd. on the plea that since the directors of this company were found to be involved in fraudulent activities, therefore, the financials of this company cannot be relied upon. Reliance was placed on the decision of Tribunal in the case ofStream International Services (P.) Ltd. v. Asstt. CIT (International Taxation) [2013] 141 ITD 492/31 taxmann.com 227 (Mum. - Trib.) and Stream International Services (P.) Ltd.'s case (supra). The assessee also placed reliance on the decision of Hyderabad Bench of the Tribunal in the case ofBrigade Global Services (P.) Ltd. v. ITO [2013] 143 ITD 59/33 taxmann.com 618.

16. It was found from records that employees' cost of sales in case of Maple e-Solution Ltd. works out to 15.62 per cent as against assessee's ratio of 48.85 per cent. Furthermore, in view of the judicial pronouncements, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Maple e-Solution Ltd. from the list of comparables.

17. The assessee has also contended for exclusion of Acropetal Technologies Ltd. on the plea that the low employee's cost to sales is 8.20 per cent as against assessee's employees cost to sales is 48.54 per cent, therefore, this company cannot be treated as comparable. The assessee placed reliance on the decision of Tribunal in the case of Stream International Services (P.) Ltd. (supra) and Brigade Global Services (P.) Ltd.'s case (supra).

18. In veiw of the judicial pronouncements, as cited above, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Acropetal Technologies from the list of comparables.

19. The assessee has also contended for exclusion of Cosmic Global Ltd. on the plea that the low employee's cost to sales is 8.20 per cent as against assessee's employees cost to sales is 48.54 per cent.

20. It was found from record that on the plea of wide variation in the employee cost, the DRP in year under consideration, has excluded Carol Hubs Ltd. since it has low employee cost. The DRP held that it has different outsourcing model. In view of above, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Cosmic Global Ltd. from the list of comparables.

21. With regard to Datamatics Financial Service Ltd., assessee submitted that the TPO obtained segmental information for ITES segment under section 133(6). However, the company in reply to notice under section 133(6) has not provided any basis for allocation of expenses. Accordingly, it was contended that it should be excluded from the list of comparables.

22. It was noted from record that the TPO has collected segmental information by issuing notice under section 133(6). The contention of assessee was that the same are not audited. In the interest of justice, this issue is restored back to the file of the Assessing Officer/TPO with a direction to provide the information collected by the TPO under section 133(6) to assessee and after calling assessee's objection decided afresh the inclusion/exclusion of Datamatics Financial Services Ltd. from the list of comparables.

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Facts in Brief: 1. &nbsp;The assessee-company was engaged in the business of providing advisory and support services to its AEs. It had entered into international transactions with the associated enterprises. 2. &nbsp;In transfer pricing report the assessee arrived at benchmarking margin at cost plus 12.33 per cent by taking fourteen comparables. However, the TPO arrived at benchmarking margin of 30.49 per cent on the basis of 19 comparables taken by him. 3. &nbsp;Accordingly, the TPO made an upward adjustment to the arm's length in relation to the international transactions entered into by the assessee-company with its associated enterprises. 4. &nbsp;The DRP set aside objections raised by the assessee. &nbsp; &nbsp;On appeal, ITAT held as under: 5. &nbsp;The matter is resoted back to the file of Assessing Officer/TPO for recomputing benchmarking margin and to determine arm's length price of assessee's international transaction of provisions of business support services. &nbsp; &nbsp;RELEVANT PARAS OF THE JUDGEMENT ARE AS UNDER: 6. &nbsp;In view of order of the Tribunal in the case of Hyundai Motors India Engg. (P.) Ltd. v. ITO [2015] 152 ITD 112/[2014] 44 taxmann.com 34 (Hyd. - Trib.) it is found that this company is not functionally comparble and it had a different employee skill set and also performed R &amp; D services and also owned intangibles. Accordingly, the TPO is directed to exclude Genesys International Corporation Ltd. from the list of comparables. [Paras 12 and 13] 7. &nbsp;With regard to e-Clerx Services (P.) Ltd., it was contended by assessee that this company is engaged in providing data analytics and data process solution to the largest brands in the world. They are recognized experts in financial services, retails and manufacturing. The assessee also brought on record the following decision of ITAT, wherein this company was excluded from the list of comparables: (i) &nbsp;Symphony Marketing Solutions India (P.) Ltd. v. ITO [2013] 38 taxmann.com 55 (Bang.) (ii) &nbsp;Hyundai Motors India Engg. (P.) Ltd.'s case (supra) (iii) &nbsp;Maersk Global Centres (India) (P.) Ltd. v. Asstt. CIT [2014] 147 ITD 83/43 taxmann.com 100 (Mum. - Trib.) (SB) and (iv) &nbsp;Lionbridge Technologies Ltd. v. ITO [2014] 151 ITD 553/48 taxmann.com 46 (Mum. - Trib.) Considering the judicial pronouncements as cited above, the Assessing Officer is directed to exclude e-Clerx Services (P.) Ltd. from the list of comparables. 8. &nbsp;The assessee also contended for exclusion of Accentia Technologies Ltd. It was found that the TPO after collecting information under section 133(6) assessee had included it as a comparable. The plea of the assessee is that it has software development activity also, therefore, non-comparable with the functional activity of the assessee. In the interest of justice, this matter is remitted back to the file of the TPO for examining afresh. The information collected by him under section 133(5) is to be supplied to assessee. It is directed accordingly. [Para 16] 9. &nbsp;The assessee has also contended for exclusion of Mold Tek Technologies Ltd. on the plea that it has extra ordinary events happened during the year, i.e., amalgamation with Tech Men Tools (P.) Ltd.&nbsp; 10. &nbsp;It was found that the ITAT Special Bench in the case of Maersk Global Centres (India) (P.) Ltd., (supra) has directed for exclusion of Mold Tek Technologies Ltd. On the plea that the financial year 2007-08 relevant to assessment year 2008-09 was a unique year for Mold Tek Technologies Ltd., as the scheme of arrangement involving amalgamation between Tekmen Tool (P.) Ltd. And Mold Tek Technologies Ltd. and de-merger between Mold Tek Technologies Ltd. Simultaneously was sanctioned by the AP High Court by 15-7-2008 with the appointed date for amalgamation and de-merger being 1-9-2007 and 1-4-2007, respectively. In view of the above, respectfully following the decision of Special Bench, the TPO is directed to exclude Mold Tek Technologies Ltd. from the list of comparables.&nbsp; 11. &nbsp;The assessee has also contended for exclusion of Infosys BPO Ltd. on the plea that it is a giant company having turnover of Rs. 825.08 crore.&nbsp; 12. &nbsp;It was found that Infosys BPO Ltd., being a subsidiary of Infosys, has an element of brand value associated with it. This is also clear from the present of brand related expenses incurred by this company. Presence of a brand commands premium price and the customers would be willing to pay, for the services/products of the company. Infosys BPO is an established player who is not only a market leader but also a company employing sheer breadth in terms of economies of scale and diversity and geographical dispersion of customers. The presence of the aforesaid factors will take this company out of the list of comparables. Therefore, the contention of the assessee that this company cannot be regarded as a comparable is accepted. 13. &nbsp;The assessee has also contended for exclusion of Wipro Ltd. on the plea that it is a giant company having turnover of Rs. 11,57.20 crores and it owns tangibles. Reliance was placed on (i) Symphony Marketing Solutions India (P.) Ltd.'s case (supra) (ii) Hyundai Motors India Engg. (P.) Ltd.'s case (supra) and (iii) Stream International Services (P.) Ltd. v. Asstt. CIT [2015] 53 taxmann.com 19 (Mum. - Trib.)&nbsp; 14. &nbsp;In view of the judicial pronouncements, the contention of the assessee that Wipro Ltd. cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude this company from the list of comparables. 15. &nbsp;The assessee has also contended for exclusion of Maple e-Solution Ltd. on the plea that since the directors of this company were found to be involved in fraudulent activities, therefore, the financials of this company cannot be relied upon. Reliance was placed on the decision of Tribunal in the case ofStream International Services (P.) Ltd. v. Asstt. CIT (International Taxation) [2013] 141 ITD 492/31 taxmann.com 227 (Mum. - Trib.) and Stream International Services (P.) Ltd.'s case (supra). The assessee also placed reliance on the decision of Hyderabad Bench of the Tribunal in the case ofBrigade Global Services (P.) Ltd. v. ITO [2013] 143 ITD 59/33 taxmann.com 618.&nbsp; 16. &nbsp;It was found from records that employees' cost of sales in case of Maple e-Solution Ltd. works out to 15.62 per cent as against assessee's ratio of 48.85 per cent. Furthermore, in view of the judicial pronouncements, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Maple e-Solution Ltd. from the list of comparables.&nbsp; 17. The assessee has also contended for exclusion of Acropetal Technologies Ltd. on the plea that the low employee's cost to sales is 8.20 per cent as against assessee's employees cost to sales is 48.54 per cent, therefore, this company cannot be treated as comparable. The assessee placed reliance on the decision of Tribunal in the case of Stream International Services (P.) Ltd. (supra) and Brigade Global Services (P.) Ltd.'s case (supra).&nbsp; 18. &nbsp;In veiw of the judicial pronouncements, as cited above, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Acropetal Technologies from the list of comparables.&nbsp; 19. &nbsp;The assessee has also contended for exclusion of Cosmic Global Ltd. on the plea that the low employee's cost to sales is 8.20 per cent as against assessee's employees cost to sales is 48.54 per cent.&nbsp; 20. &nbsp;It was found from record that on the plea of wide variation in the employee cost, the DRP in year under consideration, has excluded Carol Hubs Ltd. since it has low employee cost. The DRP held that it has different outsourcing model. In view of above, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Cosmic Global Ltd. from the list of comparables.&nbsp; 21. &nbsp;With regard to Datamatics Financial Service Ltd., assessee submitted that the TPO obtained segmental information for ITES segment under section 133(6). However, the company in reply to notice under section 133(6) has not provided any basis for allocation of expenses. Accordingly, it was contended that it should be excluded from the list of comparables.&nbsp; 22. &nbsp;It was noted from record that the TPO has collected segmental information by issuing notice under section 133(6). The contention of assessee was that the same are not audited. In the interest of justice, this issue is restored back to the file of the Assessing Officer/TPO with a direction to provide the information collected by the TPO under section 133(6) to assessee and after calling assessee's objection decided afresh the inclusion/exclusion of Datamatics Financial Services Ltd. from the list of comparables.&nbsp;

Facts in Brief: 1.  The assessee-company was engaged in the business of providing advisory and support services to its AEs. It had entered into international transactions with the associated enterprises. 2.  In transfer pricing report the assessee arrived at benchmarking margin at cost plus 12.33 per cent by taking fourteen comparables. However, the TPO arrived at benchmarking margin of 30.49 per cent on the basis of 19 comparables taken by him. 3.  Accordingly, the TPO made an upward adjustment to the arm's length in relation to the international transactions entered into by the assessee-company with its associated enterprises. 4.  The DRP set aside objections raised by the assessee.    On appeal, ITAT held as under: 5.  The matter is resoted back to the file of Assessing Officer/TPO for recomputing benchmarking margin and to determine arm's length price of assessee's international transaction of provisions of business support services.    RELEVANT PARAS OF THE JUDGEMENT ARE AS UNDER: 6.  In view of order of the Tribunal in the case of Hyundai Motors India Engg. (P.) Ltd. v. ITO [2015] 152 ITD 112/[2014] 44 taxmann.com 34 (Hyd. - Trib.) it is found that this company is not functionally comparble and it had a different employee skill set and also performed R & D services and also owned intangibles. Accordingly, the TPO is directed to exclude Genesys International Corporation Ltd. from the list of comparables. [Paras 12 and 13] 7.  With regard to e-Clerx Services (P.) Ltd., it was contended by assessee that this company is engaged in providing data analytics and data process solution to the largest brands in the world. They are recognized experts in financial services, retails and manufacturing. The assessee also brought on record the following decision of ITAT, wherein this company was excluded from the list of comparables: (i)  Symphony Marketing Solutions India (P.) Ltd. v. ITO [2013] 38 taxmann.com 55 (Bang.) (ii)  Hyundai Motors India Engg. (P.) Ltd.'s case (supra) (iii)  Maersk Global Centres (India) (P.) Ltd. v. Asstt. CIT [2014] 147 ITD 83/43 taxmann.com 100 (Mum. - Trib.) (SB) and (iv)  Lionbridge Technologies Ltd. v. ITO [2014] 151 ITD 553/48 taxmann.com 46 (Mum. - Trib.) Considering the judicial pronouncements as cited above, the Assessing Officer is directed to exclude e-Clerx Services (P.) Ltd. from the list of comparables. 8.  The assessee also contended for exclusion of Accentia Technologies Ltd. It was found that the TPO after collecting information under section 133(6) assessee had included it as a comparable. The plea of the assessee is that it has software development activity also, therefore, non-comparable with the functional activity of the assessee. In the interest of justice, this matter is remitted back to the file of the TPO for examining afresh. The information collected by him under section 133(5) is to be supplied to assessee. It is directed accordingly. [Para 16] 9.  The assessee has also contended for exclusion of Mold Tek Technologies Ltd. on the plea that it has extra ordinary events happened during the year, i.e., amalgamation with Tech Men Tools (P.) Ltd.  10.  It was found that the ITAT Special Bench in the case of Maersk Global Centres (India) (P.) Ltd., (supra) has directed for exclusion of Mold Tek Technologies Ltd. On the plea that the financial year 2007-08 relevant to assessment year 2008-09 was a unique year for Mold Tek Technologies Ltd., as the scheme of arrangement involving amalgamation between Tekmen Tool (P.) Ltd. And Mold Tek Technologies Ltd. and de-merger between Mold Tek Technologies Ltd. Simultaneously was sanctioned by the AP High Court by 15-7-2008 with the appointed date for amalgamation and de-merger being 1-9-2007 and 1-4-2007, respectively. In view of the above, respectfully following the decision of Special Bench, the TPO is directed to exclude Mold Tek Technologies Ltd. from the list of comparables.  11.  The assessee has also contended for exclusion of Infosys BPO Ltd. on the plea that it is a giant company having turnover of Rs. 825.08 crore.  12.  It was found that Infosys BPO Ltd., being a subsidiary of Infosys, has an element of brand value associated with it. This is also clear from the present of brand related expenses incurred by this company. Presence of a brand commands premium price and the customers would be willing to pay, for the services/products of the company. Infosys BPO is an established player who is not only a market leader but also a company employing sheer breadth in terms of economies of scale and diversity and geographical dispersion of customers. The presence of the aforesaid factors will take this company out of the list of comparables. Therefore, the contention of the assessee that this company cannot be regarded as a comparable is accepted. 13.  The assessee has also contended for exclusion of Wipro Ltd. on the plea that it is a giant company having turnover of Rs. 11,57.20 crores and it owns tangibles. Reliance was placed on (i) Symphony Marketing Solutions India (P.) Ltd.'s case (supra) (ii) Hyundai Motors India Engg. (P.) Ltd.'s case (supra) and (iii) Stream International Services (P.) Ltd. v. Asstt. CIT [2015] 53 taxmann.com 19 (Mum. - Trib.)  14.  In view of the judicial pronouncements, the contention of the assessee that Wipro Ltd. cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude this company from the list of comparables. 15.  The assessee has also contended for exclusion of Maple e-Solution Ltd. on the plea that since the directors of this company were found to be involved in fraudulent activities, therefore, the financials of this company cannot be relied upon. Reliance was placed on the decision of Tribunal in the case ofStream International Services (P.) Ltd. v. Asstt. CIT (International Taxation) [2013] 141 ITD 492/31 taxmann.com 227 (Mum. - Trib.) and Stream International Services (P.) Ltd.'s case (supra). The assessee also placed reliance on the decision of Hyderabad Bench of the Tribunal in the case ofBrigade Global Services (P.) Ltd. v. ITO [2013] 143 ITD 59/33 taxmann.com 618.  16.  It was found from records that employees' cost of sales in case of Maple e-Solution Ltd. works out to 15.62 per cent as against assessee's ratio of 48.85 per cent. Furthermore, in view of the judicial pronouncements, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Maple e-Solution Ltd. from the list of comparables.  17. The assessee has also contended for exclusion of Acropetal Technologies Ltd. on the plea that the low employee's cost to sales is 8.20 per cent as against assessee's employees cost to sales is 48.54 per cent, therefore, this company cannot be treated as comparable. The assessee placed reliance on the decision of Tribunal in the case of Stream International Services (P.) Ltd. (supra) and Brigade Global Services (P.) Ltd.'s case (supra).  18.  In veiw of the judicial pronouncements, as cited above, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Acropetal Technologies from the list of comparables.  19.  The assessee has also contended for exclusion of Cosmic Global Ltd. on the plea that the low employee's cost to sales is 8.20 per cent as against assessee's employees cost to sales is 48.54 per cent.  20.  It was found from record that on the plea of wide variation in the employee cost, the DRP in year under consideration, has excluded Carol Hubs Ltd. since it has low employee cost. The DRP held that it has different outsourcing model. In view of above, the contention of the assessee that this company cannot be treated as comparable is accepted. Accordingly, the TPO is directed to exclude Cosmic Global Ltd. from the list of comparables.  21.  With regard to Datamatics Financial Service Ltd., assessee submitted that the TPO obtained segmental information for ITES segment under section 133(6). However, the company in reply to notice under section 133(6) has not provided any basis for allocation of expenses. Accordingly, it was contended that it should be excluded from the list of comparables.  22.  It was noted from record that the TPO has collected segmental information by issuing notice under section 133(6). The contention of assessee was that the same are not audited. In the interest of justice, this issue is restored back to the file of the Assessing Officer/TPO with a direction to provide the information collected by the TPO under section 133(6) to assessee and after calling assessee's objection decided afresh the inclusion/exclusion of Datamatics Financial Services Ltd. from the list of comparables.

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TPO to provide info. collected u/s 133(6) I.T.Act to assessee in TP case. ITAT