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| The Tax Publishers2020 TaxPub(DT) 3081 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Extraordinary event such as merger/amalgamation had an impact/effect on profitability of M/s. Accentia Technoloties Ltd., therefore, it could not be held to be comparable to assessee's case.
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Transfer pricing - Determination of ALP - Selection of comparables - Extraordinary event
Assessee rendered IT enabled technical support services to AE abroad. TPO considered Accentia Technologeis Ltd. as comparable to assessee's case.Held: Extraordinary event such as merger/amalgamation had an impact/effect on profitability of M/s. Accentia Technoloties Ltd., therefore, it couldnot be held to be comparable to assessee's case.
Followed:PCIT v. Aptara Technology (P) Ltd. for assessment year 2008-09 reported in (2018) 303 CTR 805 (Bom) : 2018 TaxPub(DT) 5815 (Bom-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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