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| The Tax Publishers2019 TaxPub(DT) 7433 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Kals Information Systems Ltd. engaged in development of software products was functionally different company. Further, assets base of the company was Rs. 40.26 lakhs which was very miniscule as compared to assessee company which was Rs. 288.2 crores and therefore, it could be considered as comparable to assessee engaged in software development services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and miniscule asset base
Assessee rendered software development services to AE abroad. TPO considered Kals Information Systems Ltd. as comparable to assessee's case.Held: Kals Information Systems Ltd. engaged in development of software products was functionally different company. Further, assets base of the company was Rs. 40.26 lakhs which was very miniscule as compared to assessee company which was Rs. 288.2 crores. Therefore, it could be considered as comparable to assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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