The Tax Publishers2020 TaxPub(DT) 4772 (Bang-Trib)

INCOME TAX ACT, 1961

Section 92C

Acropetal Technologies Ltd. engaged in development of computer software products could not be considered as functionally comparable to assessee engaged in software development services.

Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity and failing of RPT filter

Assessee rendered software development services to its AE abroad. TPO considered Acropetal Technologies Limited as comparable to assessee's case.Held: Acropetal Technologies Ltd. engaged in development of computer software products could not be considered as functionally comparable to assessee's case.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2011-12


INCOME TAX ACT, 1961

Section 92C

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