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| The Tax Publishers2019 TaxPub(DT) 5026 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Tata Elxsi Ltd. engaged in diversified activities including product design service, innovation design, engineering service, visual computing labs, etc. could not be considered as comparable with that of pure software development service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Diversified activities
Assessee rendered software development services to its AE abroad. TPO considered Tata Elxsi Ltd. as comparable to assessee's case.Held: Tata Elxsi Ltd. engaged in diversified activities including product design service, innovation design, engineering service, visual computing labs, etc., could not be considered as comparable with that of pure software development service provider like assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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