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| The Tax Publishers2019 TaxPub(DT) 2704 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
TCS E-Serve Ltd. was engaged in technical services such as software testing, verification and validation, which required high technical expertise/ skills and methods and were purely different from IT-enabled back office support services rendered by assessee. Further, association of higher brand value of Tata and TCS had impacted its revenue and profitability in a positive manner, hence, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered IT enabled back office support services to its AE abroad. TPO considered TCS E-Serve Ltd. as comparable to assessee's case. Held: TCS E-Serve Ltd. was engaged in technical services such as software testing, verification and validation. which required high technical expertise/s skills and methods and were purely different from IT enabled back office support services. rendered by assessee. Further, association of higher brand value of Tata and TCS had impacted its revenue and profitability in a positive manner, hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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