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| The Tax Publishers2020 TaxPub(DT) 3510 (Mum-Trib) INCOME TAX ACT, 1961
Section 92C
Alphageo (India) Ltd. ('Alphageo') engaged in providing 2D and 3D seismic services including data acquisition, processing and interpretation could not be considered as functionally comparable to assessee engaged in technical support services.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity
Assessee rendered technical support services to its AE abroad. TPO considered Alphageo (India) Ltd. ('Alphageo') as comparable to assessee's case. Held: Alphageo (India) Ltd. ('Alphageo') engaged in providing 2D and 3D seismic services including data acquisition, processing and interpretation could not be considered as functionally comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour
A.Y. : 2009-10
INCOME TAX ACT, 1961
Section 92C
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