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The Tax Publishers2021 TaxPub(DT) 0051 (Bang-Trib) INCOME TAX ACT, 1961
Section 92C
TCS E-Serve Limited was engaged in delivering core business processing services, analytics/insigns (KPO) and support services for both data and voice processes. Further, the company was marked by M/s. TCS Ltd. and Tata brand equity. Accordingly, it could not be taken as suitable comparable to assessee (ITES provider).
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Transfer pricing - Determination of ALP - Selection of comparables - Significant brand value and functional dissimilarity
Assessee rendered IT enabled services to its AE abroad. TPO considered TCS E-Serve Limited as comparable to assessee's case. Held: TCS E-Serve Limited was engaged in delivering core business processing services, analytics/insigns (KPO) and support services for both data and voice processes. Further, the company was marked by M/s. TCS Ltd. and Tata brand equity. Accordingly, TCS E-Serve Ltd. could not be taken as 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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