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| The Tax Publishers2020 TaxPub(DT) 2154 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Accentia Technologies Ltd. engaged in medical transcription, billing, coding and software development and implementation services and having extraordinary event like amalgamation contributing to extraordinary growth in revenues was not functionally comparable to assessee engaged in IT enabled services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and extraordinary event
Assessee rendered IT enabled support services to its AE abroad. TPO considered Accentia Technologies Ltd. as comparable to assessee's case. Held: Accentia Technologies Ltd. engaged in medical transcription, billing, coding and software development and implementation services and having extraordinary event like amalgamation contributing to extraordinary growth in revenues was not functionally comparable to assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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