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| The Tax Publishers2019 TaxPub(DT) 8436 (Kol-Trib) INCOME TAX ACT, 1961
Section 92C
E-Infochips Bangalore Ltd. was engaged in sale of software products, software development and IT enabled services and since segmental data was not available, therefore, it could not be considered as comparable with that of assessee engaged in software development services only.
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Transfer pricing - Determination of ALP - Selection of comparables - No segmental data
Assessee rendered software-development services to its AE abroad. TPO considered E-Infochips Bangalore Ltd. as comparable to assessee's case.Held: E-Infochips Bangalore Ltd. was engaged in sale of software products, software development and IT enabled services and since segmental data was not available and, therefore, it could not be considered as comparable with that of assessee engaged in software development services only.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 92C
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