The Tax Publishers2020 TaxPub(DT) 1505 (Pune-Trib)

INCOME TAX ACT, 1961

Section 92C

Kals Information System Ltd. engaged into development of software products could not be considered as functionally comparable to assessee engaged in software development services.

Transfer pricing - Determination ALP - Selection of comparables - Functional dissimilarity

Assessee rendered software development services to AE abroad. TPO considered Kals Information System Ltd. as comparable to assessee's case. Held: Kals Information System Ltd. engaged into development of software products could not be considered as functionally comparable to assessee's case.

REFERRED :

FAVOUR : in assessee's favour

A.Y. :


INCOME TAX ACT, 1961

Section 92C

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