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| The Tax Publishers2020 TaxPub(DT) 1740 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Assessee fell under the category of companies having turnover of 1-200 crores, while Larsen and Toubro Infotech Limited and Persistent Systems Ltd. did not fall under the above said category, accordingly there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Turnover filter
Assessee rendered software development services to AE abroad. TPO considered Larsen and Toubro Infotech Limited and Persistent Systems Ltd. as comparable to assessee's case.Held: Assessee fell under the category of companies having turnover of 1-200 crores, while Larsen and Toubro Infotech Limited and Persistent Systems Ltd. did not fall under the above said category, accordingly there could be no comparability analysis.
Followed:Genisys Integrating Systems (India) (P.) Ltd. v. Dy. CIT IT(TP)A No. 1231/Bang/2010 : 2012 TaxPub(DT) 2253 (Bang-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
IN THE ITAT, BANGALORE BENCH
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