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| The Tax Publishers2020 TaxPub(DT) 3690 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
TCS E-Serve International Ltd. was having huge brand value. Further TCS E-Serve International was into ITES/BPO services and technical services which were in the natue of software testing, verifciation and validation but there was no segmental information to bifurcate income and expenditure qua both the segments, accordingly, it was not a suitable comparable for benchmarking international transactions qua ITES segment of assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Huge brand value and no segmental data
Assessee rendered IT enabled services to AE abroad. TPO considered TCS E-Serve International ltd. [TCS E-Serve International] as comparable to assessee's case.Held: TCS E-Serve International Ltd. was having huge brand value. On margin earned. Further TCS E-Serve International was into ITES/BPO services and technical services which were in the nature of software testing, verifciation and validation but there was no segmental information to bifurcate income and expenditure qua both the segments. Accordingly, it was not a suitable comparable for benchmarking international transactions qua ITES segment of assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2010-11 & 2011-12
INCOME TAX ACT, 1961
Section 92C
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