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| The Tax Publishers2019 TaxPub(DT) 1939 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Tata Elxsi engaged in development of niche product could not be considered as 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 Tata Elxsi Ltd. as comparable to assessee's case. Held: Tata Elxsi engaged in development of niche product could not be considered as comparable with that of assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2006-07
INCOME TAX ACT, 1961
Section 92C
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