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| The Tax Publishers2020 TaxPub(DT) 3677 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
TCS E-Serve and TCS E-Serve International Limited were also engaged in software testing, verification and validation of software at the time of implementation and data center management activities and no segmental information was available. Moreover, both these companies had huge brand value for having been associated with Tata brand and accordingly, these companies could not be taken as comparables to assessee engaged in ITES.
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Transfer pricing - Determination of ALP - Selection of comparables - Lack of segmental data and huge brand value
Assessee rendered IT enabled services to its AE abroad. TPO consdiered TCS E-Serve Ltd. and TCS E-Serve International Ltd. as comparable to assessee's case. Held: Although TCS E-Serve and TCS E-Serve International Limited were also engaged in software testing, verification and validation of software at the time of implementation and data center management activities, it is also true that no segmental information was available. Moreover, both these companies had huge brand value for having been associated with Tata brand and accordingly, these companies could not be taken as comparables to assessee's case.
Followed:Avaya India (P) Ltd. American Express (I) (P) Ltd. ITA No. 1426/Del/2015United Health Group ITA 1038/DEL/2015 relating to assessment year 2010-11.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11
INCOME TAX ACT, 1961
Section 92C
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