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| The Tax Publishers2020 TaxPub(DT) 1600 (Pune-Trib) : (2020) 079 ITR (Trib) 0656 INCOME TAX ACT, 1961
Section 92C
A company engaged in product development and product design services cannot be used as comparable to assessee who was a software development services provider.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
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 while assessee was a software development services provider, hence, there could be no comparability analysis.
Followed:Symantee Software India (P) ltd. v. Dy. CIT (2020) 114 Taxmann.com 435 (Pune-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2014-15
INCOME TAX ACT, 1961
Section 92C
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