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| The Tax Publishers2019 TaxPub(DT) 1937 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Avani Cincom Technologies Ltd. engaged in development of software products could not be considered as functionally comparable with that of assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered software development services to its AE abroad. TPO considered Avani Cincom Technologies Ltd. as comparable to assessee's case. Held: Avani Cincom Technologies Ltd. engaged in development of software products 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 92C
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