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| The Tax Publishers2020 TaxPub(DT) 0015 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
If contention of assessee, that related party transactions (RPT) of 3DPLM was more than 25% was found to be correct, 3DPLM Software Solutions Ltd. would be excluded from final set of comparables.
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Transfer pricing - Determination of ALP - Selection of comparables - Assessee pleading failure of 25% RPT filter applied by TPO
Assessee rendered software development services to AE abroad. TPO considered 3DPLM Software Solutions Ltd. as comparable to assessee's case. Assessee challneged this on the ground that related party transactions (RPT) of 3DPLM were more than 25% and it did not satisfy the filter applied by TPO. Held: Matter remanded. TPO was directed to verify related party transactions of 3DPLM and if contention of assessee, that RPT of 3DPLM was more than 25% was found to be correct, 3DPLM Software Solutions Ltd. would be excluded from final set of comparables.
Relied:Global Logic India Pvt. Ltd. v. Dy. CIT ITA. No. 5110 (Del) of 2010 : 2013 TaxPub(DT) 996 (Del-Trib).
REFERRED :
FAVOUR : Matter remanded.
A.Y. : 2009-10 & 2010-11
INCOME TAX ACT, 1961
Section 92C
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