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The Tax Publishers2020 TaxPub(DT) 5060 (Del-Trib) INCOME TAX ACT, 1961
Section 92C
Infosys Technologies Ltd. having huge brand value could not be taken as suitable comparable to assessee (Software Development Services Provider).
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Transfer pricing - Determination of ALP - Selection of comparables - Huge brand value
Assessee rendered software development services to its AE abroad. TPO considered Infosys Technologies Ltd. as comparable to assessee's case. Held: Infosys Technologies Ltd. having huge brand value could not be taken as suitable comparable to assessee's case.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. :
INCOME TAX ACT, 1961
Section 92C
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