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| The Tax Publishers2019 TaxPub(DT) 7968 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
As details regarding 75% revenue from software development filter, were not discussed by TPO with facts and figures, therefore, issue regarding comparability of Accropetal Technologies Ltd. was remanded to TPO for fresh adjudication.
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Transfer pricing - Determination of ALP - Selection of comparables - Revenue from software development services being less than 75% filter applied by TPO
Assessee rendered software development services to its AE abroad. TPO considered Accropetal Technologies Ltd. as comparable to assessee's case. Assessee challenged this on the ground that in case of Accropetal Technologies Ltd. revenue from software development service was Rs. 81.40 crores, out of total operating revenue of Rs. 141 crores. Thus, revenue from software development was admittedly less than 75% of total operating revenue of this company, therefore, same had to be excluded from list of comparable companies.Held: Details regarding 75% revenue from software development filter were not discussed by TPO with facts and figures. Therefore, issue regarding comparability of Accropetal Technologies Ltd. was remanded to TPO for fresh adjudication.
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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