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| The Tax Publishers2020 TaxPub(DT) 2826 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Genesys International Corporation Ltd. predominantly engaged in providing advance mapping, survey, geospatial services and providing solutions revolving state of the art remote sensing LIDAR, ariel survey could not be considered as functionally comparbale to assessee-company engaged in customized business process outsourcing services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee-company rendered customized business process outsourcing services to AE abroad. TPO considered Genesys International Corporation Ltd. as comparable to assessee's case. Held: Genesys International Corporation Ltd. predominantly engaged in providing advance mapping, survey, geospatial services and providing solutions revolving state of the art remote sensing LIDAR, ariel survey could not be considered as functionally comparable to assessee-company rendered customized business process outsourcing services.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
INCOME TAX ACT, 1961
Section 92C
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