|
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 FOR FULL CONTENT |