The Tax Publishers2020 TaxPub(DT) 5577 (Bang-Trib)

INCOME TAX ACT, 1961

Section 92C

Infosys BPO had huge value significant intangibles, extraordinary events of acquisition during the relevant year. Accordingly, it was not suitable comparable to assessee engaged in ITES.

Transfer pricing - Determination of ALP - Selection of comparbales - Significant brand value and intangibles

Assessee rendered IT enabled services to its AE abroad. TPO considered Infosys BPO Ltd. as comparable to assessee's case. Held: Infosys BPO had huge value significant intangibles, extraordinary events of acquisition during the relevant year. Accordingly, it was not suitable comparable to assessee's case.

REFERRED :

FAVOUR : In assessee's favour.

A.Y. : 2012-13


INCOME TAX ACT, 1961

Section 92C

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