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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.
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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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