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| The Tax Publishers2020 TaxPub(DT) 2436 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
KALS Information Systems Ltd. earned revenue from both software services and products for which there was no segmental details available. Also, the company was engaged in poviding training and, therefore, it could not be considered as functionally comparable to assessee engaged in providing captive software development services to AE.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and no segmental data available
Assessee rendered captive software development services to AE abroad. TPO considered KALS Information Systems Ltd. as comparable to assessee's case.Held: KALS Information Systems Ltd. earned revenue from both software services and products for which there was no segmental details available. Also, the company was engaged in poviding training and, therefore, it could not be considered as functionally comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2007-08
INCOME TAX ACT, 1961
Section 92C
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