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| The Tax Publishers2020 TaxPub(DT) 2111 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Persistent Systems and Solutions Ltd. earned income from sale of software services and products and no segmental details were available in respect of the same. Therefore, it could not be taken as comparable to pure software development service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Absence of segmental details
Assessee rendered software development services to its AE abroad. TPO considered Persistent Systems and Solutions Ltd. as comparable to assessee's case. Held: Persistent Systems and Solutions Ltd. earned income from sale of software services and products and no segmental details were available in respect of the same. Therefore, it could not be taken as comparable to pure software development service provider like assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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