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| The Tax Publishers2020 TaxPub(DT) 2596 (Bang-Trib) : (2020) 185 ITD 0634 INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. owned IPRs, brand value, focussed on R&D and operated in diversified markets and, therefore, it could not be considered as suitable to captive software service provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Significant IPRs and brand value, etc.
Assessee rendered software development services to AE abroad. TPO considered Infosys Ltd. as comparable to assessee's case. Infosys Ltd. as comparable to assessee's case.Held: Infosys Ltd. owned IPRs, brand value, focussed on R&D and operated in diversified markets and, therefore, it could not be considered as suitable to captive software service provider like assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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