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| The Tax Publishers2020 TaxPub(DT) 2153 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Mindtree Ltd. carried out research and development activities ad created large intangibles. Under such circumstances it could not be taken as comparable with that of a captive software development service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Huge intangibles
Assessee rendered software development services to AE abroad. TPo considered Mindtree Ltd. as comparable to assessee's case. Held: Mindtree Ltd. carried out research and development activities ad created large intangibles. Under such circumstances it could not be taken as comparable with that of a captive software development service provider like assessee.
REFERRED :
FAVOUR : In assesse's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 92C
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