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| The Tax Publishers2020 TaxPub(DT) 4700 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
In case of Acropetal Technologies Limited income from software development services was less than 75% of total revenue and the company was not therefore, comparable to software development services provider like assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Failing of service income filter
Assessee rendered software development services to its AE abroad. TPO considered Acropetal Technologies Limited as comparable to assessee's case. Held: In case of Acropetal Technologies Limited income from software development services was less than 75% of total revenue and the company was not therefore, comparable to software development services provider like assessee.
Relied: M/S Applied Materials India Pvt. Ltd. v. ACIT [IT(TP) A Nos. 17 & 39/Bang/2016, Order, dated 21-9-2016].
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2011-12
INCOME TAXA CT, 1961
Section 92C
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