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| The Tax Publishers2020 TaxPub(DT) 1424 (Pune-Trib) INCOME TAX ACT, 1961
Section 92C
Persistent Systems Ltd. engaged in rendering IT services and in development of software products could not be treated as comparable with regard to assessee's software development service segment, without there being support segmental inforamtion.
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Transfer pricing - Determination of ALp - Selection of comparables - Non-availability of segmental data
Assessee rendered software development services to AE abroad. TPo considered Persistent Systems Ltd. as comparable to assessee's case.Held: Persistent Systems Ltd. engaged in rendering IT services and in development of software products could not be treated as comparable company and TPO was directed to exclude Persistent Systems ltd. from final list of comparable companies with regard to its software development service segment, without there being support segmental inforamtion.
Followed:Pr. CIT v. Saxo India Pvt. Ltd. [ITA No. 682/2016] : 2016 TaxPub(DT) 4367 (Del-HC).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 92C
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