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| The Tax Publishers2020 TaxPub(DT) 5444 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
In case of Accentia Technologies Ltd., there was an influence to pricing policy because of its possession of Brand Value/IPRs. Accentia Technologies Ltd. has also made acquisition/amalgamation which depicted that company had plans to grow through tie-ups and acquisitions of other companies. Accordingly, it could not be taken as suitable comparable to assessee engaged in ITES.
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Transfer pricing - Determination of ALP - Selection of comparables - Impact of brand valule and extraordingry event
Assessee rendered IT-enabled services to its AE abroad. TPO considered Accentia Technologies Ltd. as comparable to assessee's case. Held: In case of Accentia Technologies Ltd. there was an influence to pricing policy because of its possession of Brand Value/IPRs. Accentia Technologies Ltd. has also made acquisition/amalgamation which depicted that company had plans to grow through tie-ups and acquisitions of other companies. Accordingly, it 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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