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| The Tax Publishers2020 TaxPub(DT) 3431 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Accentia Technologies Ltd. engaged in providing service to healthcare industry in the nature of medical transcription, medical coding, etc., and owning significant intangible assets in form of goodwill, etc., and also owning proprietary software products could not be considered as functionally comparable to ITES provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered IT-enabled services to its AE abroad. TPO considered Accentia Technologies Ltd. as comparables to assessee's case. Held: Accentia Technologies Ltd. engaged in providing service to healthcare industry in the nature of medical transcription, medical coding, etc., and owning significant intangible assets in form of goodwill, etc., and also owning proprietary software products could not be considered as functionally comparable to ITES provider like assessee.
Followed:E-Valueserve SEZ (Gurgaon) (P) Ltd. v. Asstt. CIT [ITA No. 5147/Del/2017] : 2018 TaxPub(DT) 6765 (Del-Trib).
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAX ACT, 1961
Section 92C
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