India-based Information technology giant Infosys Technologies Ltd. improperly departed from longstanding tax law formulas by substituting its own method of calculating income for New York corporate tax liability purposes, the state Tax Appeals Tribunal has determined.

The three-member panel in In the Matter of Infosys Technologies Limited, DTA No. 820669, rejected what Infosys contended was a fair allocation of its income attributable to its New York operations under its business model, increasingly more common in the global economy, where most of the work for its U.S. clients is performed in India because of low labor costs.