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| The Tax Publishers2020 TaxPub(DT) 1508 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
ICRA Techno Analytics Ltd. (seg)was engaged in diversified activities of software development and consultancy, engineering services, web development & hosting and substantially diversified itself into domain of business analysis and business process outsourcing, therefore, same could not be regarded as functionally comparable with that of the assessee rendering software development services alone to its AE.
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Transfer pricing - Determination of ALP - Selection of comparables - substantially diversified activities
Assessee rendered software development services to AE abroad. TPO considered ICRA Techno Analytics Ltd. (seg) as comparable to assessee's case. Held: ICRA Techno Analytics Ltd. (seg)was engaged in diversified activities of software development and consultancy, engineering services, web development & hosting and substantially diversified itself into domain of business analysis and business process outsourcing, therefore, same could not be regarded as functionally comparable with that of the assessee rendering software development services alone to its AE.
Followed: 2016) 70 taxmann.com 299 (Bangalore--Trib.) Dy. CIT, Circle-3(1)(2), Bangalore v. Electronics for Imaging India (P) Ltd. For (Assessment year 2010-11
REFERRED :
FAVOUR : in assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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