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| The Tax Publishers2019 TaxPub(DT) 3783 (Hyd-Trib) INCOME TAX ACT, 1961
Section 92C
In case of Exensys Software Solutions Ltd. there was an extra-ordinary event of merger which resulted in high operating margin of that company and, therefore, same could not be considered as good comparable to assessee's case.
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Transfer pricing - Determination of ALP - Selection of comparables - Extraordinary event
Assessee rendered software development services to its AE abroad. TPO considered Exensys Software Solutions Ltd. as comparable to assessee's case.Held: In case of Exensys Software Solutions Ltd. there was an extra-ordinary event of merger which resulted in high operating margin of that company and, therefore, same could not be considered as good comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2005-06
INCOME TAX ACT, 1961
Sedction 92C
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