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| The Tax Publishers2020 TaxPub(DT) 3398 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
L&T Infotech Limited owned brand and products and was also engaged in trading activities and had overseas delivery centers with sales and marketing, R & D activities and had presence of intangibles. Accordingly, it could not be considered as suitable comparable to assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and presence of brand and intangibles
Assessee rendered software development services to its AE abroad. TPO considered L&T Infotech Limited. as comparable to assessee's case. Held: L&T Infotech Limited owned brand and products and was also engaged in trading activities and had overseas delivery centers with sales and marketing, R & D activities and had presence of intangibles. Accordingly, it could not be considered as suitable comparable to assessee's case.
Followed:Yahoo Software India Pvt. Ltd. v. JCT () 115 Taxman.com 60 ().
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2015-16
INCOME TAX ACT, 1961
Section 92C
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