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| The Tax Publishers2020 TaxPub(DT) 2118 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Acropetal Technoloties Ltd. L&T Infotech Ltd. were not functionally similar with that of assessee, who was a contract software development service provider, working on a cost plus business model, hence, there could be no comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Different business model
Assessee rendered software development services to AE abroad. TPO considered Acropetal Technoloties Ltd., L&T Infotech Ltd. as comparable to assesse's case.Held: Acropetal Technoloties Ltd. L&T Infotech Ltd. were not functionally similar with that of assessee, who was a contract service provider, working on a cost plus business model, hence, there could be no comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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