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| The Tax Publishers2020 TaxPub(DT) 1772 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Thirdware Solutions (P) Ltd. was engaged into diversified activities and derived income from sale of software licence, software products apart from software development services, therefore, it could not be considered as good comparable to captive software development services provider like assessee in the absence of segmental data.
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Transfer pricing - Determination of ALP - Selection of comparables - Diversified activites and no segmental data
Assessee rendered software development services to AE abroad. TPO considered Thidware Solutions (P) Ltd. as comparable to assessee's case.Held: Thirdware Solutions (P) Ltd. was engaged into diversified activities and derived income from sale of software licence, software products apart from software development services and no separate segmental was available. Therefore, this company could not be considered as good comparable to captive software development services provider like assessee.
Followed:ITO v. Net Devices India (P) ltd. IT(TP)A No. 1099/Bang/2011 vide Order, dated 25-5-2016 and further vide Order, dated 23-11-2016 in MP No. 100/Bang/2016.
REFERRED :
FAVOUR : In assedssee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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