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| The Tax Publishers2020 TaxPub(DT) 0944 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Revenue of Mitcon from services was only 60% which was below the filter of 75% adopted by TPO. Further, Mitcon was functionally dissimilar to assessee as it was providing solution in power, energy efficiency, renewable energy, climate change and environmental management sector etc., hence, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Service income filter
Assessee rendered engineering consultancy services to AE abroad. TPO considered M/S. MITCON CONSULTANCY & ENGINEERING SERVICES LTD. as comparable to assessee's case. Held: Revenue of Mitcon from services was only 60% which was below the filter of 75% adopted by TPO. Further, Mitcon was functionally dissimilar to assessee as it was providing solution in power, energy efficiency, renewable energy, climate change and environmental management sector etc., hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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