The Tax Publishers2020 TaxPub(DT) 3259 (Pune-Trib)

INCOME TAX ACT, 1961

Section 92C

Since entire income of Coral Hub had been shown as income from IT-enabled services and, hence, it was to be considered as comparable to assessee engaged in design engineering services.

Transfer pricing - Determination of ALP - Selection of comparables - Functional similarity

Assessee rendered design engineering services to its AE abroad. TPO considered Coral Hub Limited as not comparable to assessee's case. Held: As evident from annual report of Coral Hub Ltd., entire income of Coral Hub had been shown as income from IT-enabled services and, hence, it was to be considered as comparable to assessee's case.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2011-12


INCOME TAX ACT, 1961

Section 92C

SUBSCRIBE TaxPublishers.inSUBSCRIBE FOR FULL CONTENT