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| The Tax Publishers2020 TaxPub(DT) 5621 (Bang-Trib) : (2020) 084 ITR (Trib) 0277 INCOME TAX ACT, 1961
Section 92C
Infosys Ltd. was a giant risk taking company and engaged in development and sale of software products and also owned intangible assets and therefore, could not be taken as comparable with software development service provider such as assessee.
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Transfer pricing - Determination of ALP - Selection of comparables - Functional dissimilarity, significant risk profile and intangibles
Assessee rendered software development services to its AE abroad. TPO considered. Infosys Ltd. as comparable to assessee's case. Held: Infosys Ltd. was a giant risk taking company and engaged in development and sale of software products and also owned intangible assets and therefore, could not be taken as comparable with software development service provider such as assessee.
REFERRED :
FAVOUR : In assessee's favour.
A.Y. : 2012-13
INCOME TAX ACT, 1961
Section 92C
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