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| The Tax Publishers2020 TaxPub(DT) 0427 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Acropetal Technologies Ltd. followed different modules and sub-contracted majority of it work to third party vendor. Further it failed revenue filter of 75% applied by TPO as income from Software Development Services. Admittedly less than 75% of total operating revenue of the company. Therefore, it had to be excluded from the list of comparable.
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Transfer pricing - Determination of ALP - Selection of comparables - Different business module and failure of revenue filter
Assessee rendered software development services to AE abroad. TPO considered Acropetal Technologies Ltd. as comparable to assessee's case.Held: Acropetal Technologies Ltd. followed different modules and sub-contracted majority of it work to third party vendor. Further it failed revenue filter of 75% applied by TPO as income from Software Development Services. Admittedly less than 75% of total operating revenue of the company. Therefore, it had to be excluded from the list of comparable.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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