| |
| The Tax Publishers2020 TaxPub(DT) 1598 (P&H-HC) : (2020) 421 ITR 0655 INCOME TAX ACT, 1961
Section 92C
Persistent Systems Ltd. was engaged in product development and product design services, and in the absence of segmental details/information, there could be no comparability analysis with assessee engaged in software development services alone.
|
Transfer pricing - Determination of ALP - Selection of comparables - Absence of segmental details/information
Assessee rendered software development services to AE abroad. TPO considered Persistent Systems Ltd. as comparable to assessee's case. Held: Persistent Systems Ltd. was engaged in product development and product design services, and in the absence of segmental details/information, there could be no comparability analysis.
Followed: Telecordia Technologies India (P) Ltd. v. Asstt. 0712012] 137 ITD 1/22 taxmann.com 96 (Mum)
REFERRED :
FAVOUR : in assessee's favour
A.Y. :
Section 92C
 SUBSCRIBE FOR FULL CONTENT
|