ITAT excludes Infosys as Comparable due to diversified operations & High Turnover

ACIT Vs Avaya India Pvt. Ltd. (ITAT Delhi) In the case of ACIT vs. Avaya India Pvt. Ltd. (Income Tax Appellate Tribunal, Delhi), the main issue is the exclusion of Infosys Ltd. as a comparable in determining the arm’s length price for the international transactions carried out by Avaya India Pvt. Ltd. The detailed analysis of this case is as follows: 1. Background: Avaya India Pvt. Ltd. is an Indian company engaged in software development and IT-enabled services. It had international transactions with its overseas associates and enterprises. The company used the Transactional Net Margin ...