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| The Tax Publishers2019 TaxPub(DT) 7247 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Margin of Avani Cimon Technologies Ltd. was 52.59% which represented abnormal circumstances and profits and, therefore, it could not be considered as suitable comparable to assessee's case.
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Transfer pricing - Determination of ALP - Selection of comparables - Abnormal profit
Assessee rendered software development serices to its AE abroad. TPO considered Avani Cimcon Technologies Ltd. as comparable to assessee's case.Held:Margin of Avani Cimon Technologies Ltd. was 52.59% which represented abnormal circumstances and profits and, therefore, it could not be considered as suitable comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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