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| The Tax Publishers2021 TaxPub(DT) 1577 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. had presence of significant intangibles assets and brand and was engaged in product development and was, therefore, functionally not comparable to assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - Significant intangible assets and brand value
Assessee rendered software development servcies to its AE abroad. TPO considered Infosys Ltd. as comparable to assessee's case. Held: Infosys Ltd. had presence of significant intangibles assets and brand and was engaged in product development and was, therefore, functionally not comparable to assessee engaged in software development services.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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