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| The Tax Publishers2019 TaxPub(DT) 1525 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
There was extraordinary event of amalgamation and demerger, in case of Mold Tek Technologies Ltd., further, the company was rendering web designing and development of services with expertise, hence, it could not be considered as functionally comparable with that of assessee engaged in low end IT enabled services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered IT enabled back end support services to its AE abroad. TPO considered Mold Tek Technologies Ltd. as comparable to assessee's case.Held: There was extraordinary event of amalgamation and demerger, in case of Mold Tek Technologies Ltd., further, the company was rendering web designing and development of services with expertise, hence, it could not be considered as functionally comparable with that of assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 10A
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