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| The Tax Publishers2021 TaxPub(DT) 2389 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
ICRA Techno Analytics Ltd. was engaged in diversified activities of software development and consultancy, engineering services, web development and housing and substantially diversified itself into domain of business analysis and business process outsourcing for which no segmental information was available, could not be regarded as functionally comparable with that of assessee who was rendering software development services to its AE.
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Transfer pricing - Determination of ALP - Selection of comparables - Diversified activities and no segmental data
Assessee rendered software development services to its AE abroad. TPO considered ICRA Techno Analytics Ltd. as comparable to assessee's case. Held: ICRA Techno Analytics Ltd. was engaged in diversified activities of software development and consultancy, engineering services, web development and housing and substantially diversified itself into domain of business analysis and business process outsourcing for which no segmental information was available and, therefore, same could not be regarded as functionally comparable with that of assessee who was rendering software development services to its AE.
Relied:Dy. CIT v. M/s. Electronics for Imaging India (P) Ltd. In IT(TP)A No. 212/Bang/2015 for assessment year 2010-2011, vide Order, dated 24-2-2016 : 2016 TaxPub(DT) 3050 (Bang-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-2011
INCOME TAX ACT, 1961
Section 92C
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