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The Tax PublishersITA No. 2029/Bang/2017 and IT (TP) A No. 2142/Bang/2017
2021 TaxPub(DT) 0421 (Bang-Trib)INCOME TAX ACT, 1961
Section 92C
Avani Cimcon Technologies Ltd. had revenue from software product also and in the absence of segmental details, Avai Cincom could not be considered as comparable to assessee who was rendering software development services only.
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Transfer pricing - Determination of ALP - Selection of comparables - Absence of segmental details
Assessee rendered software development services to its AE abroad. TPO considered Avani Cimcon Technologies Ltd. as comparable to assessee's case. Held: Avani Cimcon Technologies Ltd. had revenue from software product also and in the absence of segmental details, Avai Cincom could not be considered as comparable to assessee who was rendering software development services only.
Followed:Sonus Networks India Pvt. Ltd. v. Dy. CIT IT (TP) A No. 1365/Bang/2001, Order, dated 28-6-2019 for assessment year 2007-08.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2007-08
INCOME TAX ACT, 1961
Section 92C
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