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| The Tax Publishers2020 TaxPub(DT) 2644 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
Avani Cimcon Technologies Ltd. having revenue from software product sales apart from rendering of software services could not in the absence of segmental details could not be considered as comparable to assessee who was rendering software development services alone.
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Transfer pricing - Determination of ALP - Selection of comparables - Absence of segmental details
Assessee rendered software development services to AE abroad. TPo considered Avani Cimcon Technologies Ltd. as comparable to assessee's case. Held: Avani Cimcon Technologies Ltd. had revenue from software product sales apart from rendering of software services and in the absence of segmental details, Avani Cincom could not be considered as comparable to assessee who was rendering software development services only that too when growth rate of Avani Cincom was double the industry average.
Followed:NXP Semiconductors (P) Ltd. v. Asstt. CIT Order, dated 14-11-2014 for the assessment year 2007-08 in IT(TP)A No. 1174/Bang/2011.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2007-08
INCOME TAX ACT, 1961
Section 92C
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