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| The Tax Publishers2020 TaxPub(DT) 0314 (P&H-HC) : (2020) 420 ITR 0052 : (2020) 274 TAXMAN 0529 INCOME TAX ACT, 1961
Section 92C
Accentia Technologies engaged in software products and medical transcription could not be considered as functionally similar to assessee engaged in ITES. Further, on account of extraordinary events during the relevant year in case of said company, there could be no comparability analysis. Findings recorded by the Tribunal did not warrant any interference.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and extra ordinary event
Assessee rendered IT-enabled services to its AE abroad TPO considered Accentia Technologies Ltd. as comparable to assessee's case. Tribunal reversed this.Held: Accentia Technologies engaged in software products and medical transcription could not be considered as functionally similar to assessee engaged in ITES. Further, on account of extraordinary events during the relevant year in case of said company, there could be no comparability analysis. Findings recorded by the Tribunal did not warrant any interference.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2008-09
INCOME TAX ACT, 1961
Section 92C
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