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| The Tax Publishers2020 TaxPub(DT) 1817 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Advance Technology Limited, Empower Industries India Limited, Sonata Information Technology Limited and Svam Software Limited primarily engaged in distribution of software product were duly comparable to assessee engaged in distribution of satellite channels and TPO was dirercted to include these entities.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional similarity
Assessee engaged in distribution of satellite channels to Local Cable Operators ('LCOs'), Multi System Operators ('MSOs') and Direct to Home ('DTH') operators received distribution fee from AE abroad. TPO considered Advance Technology Limited, Empower Industries India Limited, Sonata Information Technology Limited and Svam Software Limited as not comparables to assessee's case.Held: Advance Technology Limited, Empower Industries India Limited, Sonata Information Technology Limited and Svam Software Limited primarily engaged in distribution of software product were duly comparable to assessee engaged in distribution of satellite channels. TPO was dirercted accordingly.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
IN THE ITAT, MUMBAI BENCH
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