| |
| The Tax Publishers2020 TaxPub(DT) 0798 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. was functionally not comparable with that of assessee as it was engaged in providing diversify activities like business consulting, technology, engineering and outsourcing services. The company was a giant risk-taking company and was engaged in development and sale of software products and owned intangible assets. Under such circumstances, it had to be excluded from list of comparables.
|
Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and significant intangibles
Assessee rendered software development servcies to AE abroad. TPO considered Infosys Ltd. as comparable to assessee's case.Held: Infosys Ltd. was functionally not comparable with that of assessee as it was engaged in providing diversify activities like business consulting, technology, engineering and outsourcing services. The company was a giant risk-taking company and was engaged in development and sale of software products and owned intangible assets. Under such circumstances, it had to be excluded from list of comparables.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
 SUBSCRIBE FOR FULL CONTENT
OR Try Reload the Page |