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The Tax PublishersIT(TP)A No. 349/Bang/2014, IT(TP)A No. 878/Bang/2014
2020 TaxPub(DT) 4849 (Bang-Trib)INCOME TAX ACT, 1961
Section 92C
Bodhtree Consulting Ltd. was engaged in both Software Development Services and was also in providing Information Technology Enabled Services (ITES) and break-up of revenues from diverse segments was not available and hence, it could not be taken as comparable to assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - No segmental data
Assessee rendered software development services to its AE abroad. TPO considered Bodhtree Consulting Ltd. as comparable to assessee's case. Held: Bodhtree Consulting Ltd. was engaged in both Software Development Services and was also in providing Information Technology Enabled Services (ITES) and break-up of revenues from diverse segments was not available and hence, it could not be taken as comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2005-06
INCOME TAX ACT, 1961
Section 92C
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