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| The Tax Publishers2020 TaxPub(DT) 1525 (Mum-Trib) INCOME TAX ACT, 1961
SECTION 92C
Apitco Ltd. was a Government company. It generated revenue from services such as cluster development, project development services, entrepreneurship development and training, asset reconstruction and management services, micro enterprises development, tourism and research studies, skill development, energy and environment management related services. Therefore, being a Government company and functionally different from that of support service provider like assesse it had to be excluded from the list of comparables.
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Transfer pricing-Determination of ALP - Selection of comparables - Government company and functional dissimilarity -
Assessee-company is engaged in distribution of Satellite Television Channels rendered business support services to AE abroad. TPO considered Apitco Ltd. as comparable to assessee's case. Held: Apitco Ltd. was a Government company. It generated revenue from services such as cluster development, project development services, entrepreneurship development and training, asset reconstruction and management services, micro enterprises development, tourism and research studies, skill development, energy and environment management related services. Therefore, being a Government company and functionally different from that of support service provider like assesse it had to be excluded from the list of comparables.
REFERRED :
FAVOUR : In assessee's favour
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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