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| The Tax Publishers2019 TaxPub(DT) 3230 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Accentia Technologies Ltd. was engaged in medical transcription services and had a significant amount of brands, IPRS and goodwill. Further due to extraordinary event of amalgamation, it could not be considered as suitable comparable with that of assessee engaged in IT support services.
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Transfer pricing - Determination of ALP - Selection of comparbales - Functional dissimilarity
Assessee rendered IT support services to its AE abroad. TPO considered Accentia Technologies Ltd. as comparable to assessee's case. Held: Accentia Technologies Ltd. was engaged in medical transcription services and had a significant amount of brands, IPRS and goodwill. Further, due to extraordinary event of amalgamation, it could not be considered as suitable comparable with that of assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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