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| The Tax Publishers2020 TaxPub(DT) 3535 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
CGVAX Software & Exports Limited was not only engaged in software development services but also engaged in product manufacturing process, whereas assessee was not in product manufacture activity and in the absence of relevant segmental data, there could not be comparability analysis.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and lack of segmental data
Assessee rendered software development services to its AE abroad. TPO considered CG Vak Softwre Exports Ltd. as comparable to assessee's case. Held: CGVAX Software & Exports Limited was not only engaged in software development services but also engaged in product manufacturing process, whereas assessee was not in product manufacture activity and in the absence of relevant segmental data, there could not be comparability analysis.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2013-14
INCOME TAX ACT, 1961
Section 92C
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