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| The Tax Publishers2020 TaxPub(DT) 1787 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Celestial Labs Ltd. basically/admittedly engaged in clinical research and manufacture of bio-products and other products could not be considered as functionally comparable to assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered software development services to AE abraod. TPO considered Celstial Labs Ltd. as comparable to assessee's case. Held: Celestial Labs Ltd. basically/admittedly engaged in clinical research and manufacture of bio-products and other products could not be considered as functionally comparable to assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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