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| The Tax Publishers2019 TaxPub(DT) 7636 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. had turnover of 476 times more than assessee's turnover and had a brand value and significant intangible assets. Also, Infosys Ltd. was engaged in diversified services including design as well as technical consultancy, consulting re-engineering, maintenance, systems integration as well as products for banking industry., accordingly, it could not be considered as suitable comparbale to captive software service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Huge turnover and significant brand value
Assessee rendered software development services to AE abroad. TPO considered Infosys Ltd. as comparable to assessee's case.Held: Infosys Ltd. had turnover of 476 times more than assessee's turnover and had a brand value and significant intangible assets. Also, Infosys Ltd. was engaged in diversified services including design as well as technical consultancy, consulting re-engineering, maintenance, systems integration as well as products for banking industry., accordingly, it could not be considered as suitable comparable to captive software service provider like assessee.
Relied:CGI Information Systems and Management Consultants Pvt. Ltd. IT(TP)A No. 346/Bang/2015 for assessment year 2010-11.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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